Where’s the airplane? Photos from Greenacres, Florida, show a crater in Military Trail, a burned mobile home, scorched pavement, and a column of black smoke. There is no plane. No wing, no tail section in somebody’s yard, nothing you would recognize from photos. I’ll break down why, but in truck recon crash math.

This is the anatomy of the crash, the anatomy of the investigation that started the moment it hit, and where both line up with what we do on the highway.

I am trained to reconstruct truck crashes. My training runs through the Institute of Police Technology and Management, Northwestern University’s heavy vehicle forensic and crash recon programs, the National Transportation Safety Board’s highway crash investigation course (one of the last before they closed this to the public about 6 years ago), the International Association of Arson Investigators’ fire curricula, and a host of others. My casework runs from interstate rear-end fatalities to tanker fires. Airplanes are a different machine, with a different investigating agency and a different rulebook. The physics is not different. Energy is energy and momentum is momentum, and the same equations I use to back a truck’s speed out of its crush damage explain why almost nothing is left of this jet.

The Federal Aviation Administration said the Learjet 60 departed Austin-Bergstrom International Airport bound for North Eleuthera Airport in the Bahamas with nine people aboard and crashed at about 12:50 p.m. Transportation Secretary Sean Duffy said all nine were killed. The FAA said the jet fell from 35,250 feet to 8,750 feet in a little over a minute, about 350 feet per second. On air traffic control audio captured by LiveATC.net, the crew reported light clear ice, moderate turbulence and an outside air temperature of minus 47 degrees Celsius, picked up precipitation, asked for and received a climb to 37,000 feet, then declared a mayday and reported an overspeed condition. The last words to the controller were, “We’re going to crash into the ground.”

Whether recon or claim management, In a truck case, the first thing I build is a time-and-distance picture. I pull the engine control module, CDR, etc., the electronic logging device, the telematics and the dash camera, and I lay the event out second by second. Aviation has its own black boxes, and we’ll get to those, but the public already has the equivalent of telematics: ADS-B, the position and altitude data the jet broadcast as it flew. A radar and track analysis built on National Weather Service Miami Level II radar puts the jet at 35,250 feet at 17:48:07 UTC after it was lifted by an updraft in a storm core, at 31,350 feet at 17:48:39 and at 8,750 feet, the last valid altitude, at 17:49:23.

Subtraction in planes is the same as subtraction in a highway skid analysis. In the first 32 seconds, the jet lost 3,900 feet, about 7,300 feet per minute, which lines up with the crew’s radio call of 8,000 feet per minute. In the next 44 seconds, it lost 22,600 feet. That’s about 30,800 feet per minute, or 514 feet per second straight down. Total: 26,500 feet in 76 seconds, which matches the FAA’s 350 feet per second average.

Speed. Flight tracking at 10,125 feet showed a ground speed of 298 knots and a vertical speed of 30,976 feet per minute down. In truck reconstruction, when a vehicle is moving in two directions at once, you resolve the vectors. Here, 298 knots is about 503 feet per second forward and 30,976 feet per minute is about 516 feet per second down. The square root of the sum of the squares gives a speed along the flight path of about 721 feet per second, or 491 mph, with the nose pointed roughly 46 degrees below the horizon. Video of the final seconds shows it steeper still. From 8,750 feet at that descent rate, the jet had about 17 seconds left.

Every energy calculation starts with mass. On a truck case, I pull it from the bill of lading and the scale tickets. Here I start with the manufacturer’s numbers: a standard basic operating weight of 14,772 pounds, a maximum zero fuel weight of 17,000 pounds and a maximum takeoff weight of 23,500 pounds. Add seven passengers and their bags, then subtract the fuel burned over two hours and 13 minutes at the type’s typical 230 to 250 gallons per hour, and my estimate of the jet’s weight at impact is about 18,500 pounds, or 8,400 kilograms. The NTSB will have the actual load sheet. A thousand-pound swing either way doesn’t change anything.

So..why the crater? Well, Kinetic energy equals one half the mass times the velocity squared. I spend a lot of time in front of juries explaining what that squared term means: double the speed and you quadruple the energy. At 18,500 pounds and 491 mph, N722BD was carrying about 203 megajoules of energy. That’s the equivalent of roughly 107 pounds of TNT.

In truck terms, A fully loaded 80,000-pound tractor-trailer at 65 mph carries about 15.3 megajoules. The Learjet weighed less than a quarter of that truck and carried 13 times its energy, because it was moving 7.5 times faster and 7.5 squared is about 57. A 4,000-pound car at 60 mph carries about 0.65 megajoules. The jet carried about 300 times that. This is also why I have written extensively on what a truck means when a tanker full of fuel becomes weaponized in an act of terror. Different articles, some already written but a consideration and shameless plug to drive this home.

Momentum has its own story. Momentum is mass times velocity, not velocity squared. The jet’s momentum was about 1.84 million kilogram meters per second against about 1.05 million for the loaded truck, only 1.75 times as much. In recon, we say momentum tells you where things go and energy tells you how much gets destroyed. In a truck-and-car collision, I use conservation of momentum to work out departure angles and speeds. This crash had nothing to collide with but the earth. All of it was energy, and it all had to go somewhere in a fraction of a second.

On the highway and in trucks, we measure crush and we map how far a bumper, frame rail, or cab was pushed in, apply stiffness coefficients for that vehicle and calculate the energy the structure absorbed. Truck frames and car crumple zones are built to absorb energy and protect the people inside. A jet fuselage is a thin aluminum tube that’s mostly air, built to hold cabin pressure and carry flight loads. It was never built to stop itself against the ground at 491 mph, and against 203 megajoules, its crush capacity is close to zero.

Engineers who design nuclear plant containment structures against aircraft impact use a load-and-time method that treats the airplane as crushing progressively from the nose back while the rest of it keeps arriving at full speed. Applied to this Learjet 60, it is 58 feet, 8 inches long, about 17.9 meters. Divide that length by a speed of 219.6 meters per second and the entire airframe arrives at the impact point in about 0.08 seconds. Average force is roughly the airframe’s mass per meter times velocity squared, which works out to about 22.6 meganewtons, or 5 million pounds of force, sustained for 80 milliseconds. The peaks would be higher where the engines and the wing box hit.

For the people aboard, deceleration is velocity squared divided by twice the stopping distance. If the cabin stopped over 16 feet of collapsing structure and soil, that’s about 490 times the force of gravity. Over 10 feet, it’s about 820 g. Air Force Col. John Paul Stapp rode a rocket sled to 46.2 g in 1954 and survived, and that run is still the benchmark for human tolerance. This impact was 10 to 20 times past it. Nobody survives that, and they would not have known it happened.

On April 19, 1988, Sandia National Laboratories ran a real F-4 Phantom fighter on a rocket sled into a 12-foot-thick concrete block at a nominal 215 meters per second, about 480 mph. That’s within a few miles per hour of this crash. Sandia found that the engines caused most of the impact force. The high-speed film shows the rest of the airframe dissolving against the wall.

On Oct. 25, 1999, the Learjet 35 carrying golfer Payne Stewart hit a field near Aberdeen, South Dakota, at a steep angle and at about 600 mph, according to the lead federal investigator at the time. It left a crater 42 feet long, 21 feet wide and 8 feet deep, and a reporter at the scene described the airplane as reduced to little pieces of metal. The NTSB report for that is here

As a betting man, I estimate that N722BD still had 2,000 to 2,500 pounds of Jet A aboard. At about 43 megajoules per kilogram, 2,300 pounds of fuel holds roughly 45,000 megajoules of chemical energy, about 220 times the energy of the impact itself. On a truck fire, I’m used to a pair of saddle tanks feeding a fire that takes a tractor down to the frame. Here, the impact atomized the fuel, and the fire worked on what it left. Open fuel fires burn well past aluminum’s 1,220-degree Fahrenheit melting point. What survives a crash like this is the dense stuff like engine cores, landing gear, heavy fittings, and fragments.

That’s the anatomy of the crash. The anatomy of the investigation is where trucks and planes start to look like cousins.

On a fatal truck crash, the scene belongs to state or local police and their reconstruction team. A Commercial Vehicle Safety Alliance inspector may do a post-crash Level I inspection. The NTSB takes only a small number of highway crashes. Within hours, the carrier’s insurer has a rapid response team rolling, plaintiff lawyers are sending preservation letters, and everybody is racing to lock down the ECM, the ELD records, the telematics and the camera footage before they’re overwritten.

In aviation, the NTSB has the lead from the first minute, and it said it was sending a go-team with a media briefing set for Monday in West Palm Beach. The FAA supports. The NTSB’s party system brings in the operator and manufacturers, here likely Bombardier and engine maker Pratt and Whitney Canada, under the board’s control. A preliminary report usually comes within about 30 days and a final probable cause determination in 12 to 24 months. The data sources rhyme with mine. ADS-B is the telematics. The ATC recording is the 911 call and the dispatch log. Federal charter rules generally require a cockpit voice recorder on a two-pilot turbine jet with six or more passenger seats, so investigators will look for one in the crater. Maintenance logs, training records and duty time are the driver qualification file and the hours-of-service audit.

On a truck, my black boxes are the engine control module, which on most heavy diesels stores hard-brake and last-stop event data, plus the telematics unit, the ELD and the cameras. None of it is built to survive a crash. It survives by luck, and you have to download it. Passenger cars are different: 49 CFR Part 563 standardizes the event data recorders most of them carry, and reconstructionists read them with the Bosch CDR tool. Heavy trucks have no such mandate. An airplane’s recorders are built for exactly this kind of day. The NTSB lists the survival standard for cockpit voice and flight data recorders as a 3,400 g impact for 6.5 milliseconds and a 1,100-degree Celsius fire for 30 minutes, four to seven times the average deceleration this crash produced. Charter rules require a cockpit voice recorder on a two-pilot turbine jet like this one, but the charter flight data recorder rule starts at 10 passenger seats, so this jet may not have carried one. If it didn’t, ADS-B, radar, the voice recorder and whatever the avionics and engine controllers stored become the core of the reconstruction. If the voice recorder came through the fire, it will tell investigators more than any truck download ever told me.

A highway crash report forces you to document the scene before it changes, and the same checklist applies here. Light and visibility: midday, with storms in the area. Surface: dashcam video shows a wet roadway. The scene diagram: the crater, the debris field and the area of impact get mapped, now usually with drone photogrammetry and a total station, the same tools we use on an interstate. Witnesses: the dashcam and phone videos of the final dive are the independent witnesses, and they need the same authentication and timing work I’d do on a truck’s dashcam. Third parties: a mobile home was destroyed, power went out across the area and about 600 people in a nearby community were expected to be relocated. Hazardous materials: burning jet fuel in a roadway and the storm drains under it is an environmental cleanup, and the Village of Palm Springs said it was monitoring the effect on water and sewer service. Emergency response: Palm Beach County Fire Rescue declared a mass casualty incident. Every one of those boxes is in a Florida long-form crash report, and every one will be in the NTSB docket.

The first question I always ask on a truck case is who the motor carrier was. Who held operational control, who dispatched the load, who owned the equipment, who brokered the freight. Aviation asks the same question in different words. FAA records list the jet’s registered owner as LR60271 LLC, a Delaware company using a registered agent’s address in Wilmington. Industry fleet listings place N722BD on the Part 135 charter certificate of Aurora Aviation Inc., which does business as Upper Jets at Fort Lauderdale Executive Airport. A Florida charter marketplace advertised the tail for booking. Owner, certificate holder and seller of the trip are three different companies. Anyone who has worked a trucking case with an equipment LLC, a motor carrier and a broker will recognize the structure. Whether this flight was flown as a charter or as a private flight is one of the first things the NTSB will nail down, because the rules, the training and the liability all follow from it.

Then there’s weather. Usually in litigation where weather plays a part, there are weather expert witnesses that will come in and we work with them to review weather at the time. NWS Miami radar shows the jet level at 35,000 feet inside a thin anvil cloud at 12:46 p.m., then entering the core of a thunderstorm at 12:47:51 with storm tops near 45,000 feet, reflectivity of 25 to 35 dBZ at its own altitude and an updraft strong enough to lift it to 35,250 feet before it began to fall. A separate radar and temperature review posted on X describes the same cell as a rapidly building convective tower that lofted heavy moisture and put the jet inside it at 12:47 to 12:48 p.m. FAA thunderstorm guidance tells pilots to regard any storm with tops at 35,000 feet or higher as extremely hazardous and to stay at least 20 miles from any storm that is severe or shows an intense radar echo. A highway crash report asks the same question in plainer words: what were the weather and road conditions, and did the driver adjust to them? A trucker who drives into a squall line at 70 mph gets judged under 392.14. A flight crew that flies into a building thunderstorm gets judged against that guidance, the weather radar on the panel and whatever the operator’s manual told them to do.

On the radio, the crew reported ice at minus 47 Celsius. Supercooled liquid water essentially can’t exist below about minus 40, so whatever was hitting that airplane was more likely ice crystals than the wet, clear ice that builds on wings at lower altitudes. Ice crystals in the core of a thunderstorm are known to clog the pitot probes that feed airspeed indications, which is what started the chain on Air France Flight 447 in 2009. An overspeed call, a steep bank in a transcript of the recording circulating online, and a spiral that tightens as the nose drops would all be consistent with an upset in convective weather. Consistent is not proven. Some people reviewing dashcam footage claim the tail was missing on the way down. That isn’t verified, and the debris field will settle it. If pieces of the tail turn up away from the crater, the airplane began breaking up in flight. On the highway, we read a debris field the same way: parts upstream of the point of impact tell you something was let go before the collision.

Human factors are part of every truck reconstruction I do, and they’ll be part of this one. Experience, training, duty time and the decision to fly through that line of weather will all be examined. The crew and passenger names have not been officially released. Social media has already named the pilot as Nathalia Filgueiras. Nobody should build a story on it until the medical examiner and the NTSB confirm it. In my world, a deposition doesn’t overrule the logbook. Online speculation doesn’t overrule the investigation. She can be seen flying here:

When I take a truck case, the crash itself is half the file. The other half is paper, and we pull it the same way every time: the driver qualification file, the hours-of-service records, the drug and alcohol testing history, the medical card, the license and endorsements, the training records, and the maintenance file on the tractor and trailer. The NTSB pulls the same categories on an airplane. The regulation numbers change. The questions don’t.

FMCSA sorts that paper into seven buckets it calls BASICs, the Behavior Analysis and Safety Improvement Categories behind its Safety Measurement System: Unsafe Driving, Crash Indicator, Hours of Service Compliance, Vehicle Maintenance, Controlled Substances and Alcohol, Hazardous Materials Compliance and Driver Fitness. Aviation regulates almost all of those categories, often more strictly. What it lacks is a scoreboard. The FAA publishes no public safety score for charter operators comparable to the SMS percentiles anyone can pull on a motor carrier, so charter customers lean on private audit ratings from firms such as ARGUS and Wyvern. When you review the BASICs one at a time, overlaps and gaps show up fast.

Who was qualified to sit in the seat. I started working on my pilot’s license here in Virginia and I was shocked that for $12,000 and a 40-hour course I could have a pilot’s license to fly a plane.

A tractor-trailer driver needs a Class A commercial driver’s license under 49 CFR Part 383, entry-level driver training under Part 380 for anyone licensed since February 2022, and a driver qualification file under Part 391 that includes a road test, a motor vehicle record review and an inquiry into the last three years of employers. Charter captains are held to a higher standard. If this trip was flown under Part 135 with paying passengers, the pilot in command of a turbojet had to hold an airline transport pilot certificate with a Learjet type rating under 14 CFR 135.243. An unrestricted ATP requires a pilot to be at least 23 years old with 1,500 hours of flight time under 14 CFR 61.153 and 61.159. The second in command needs a commercial certificate with an instrument rating under 14 CFR 135.245. If the trip was flown under Part 91 as a private flight, those charter floors fall away and the legal minimums drop sharply. That is why the Part 91 versus Part 135 question matters so much. It’s the aviation version of asking whether a truck was running as a for-hire motor carrier or a private carrier. Once the crew is officially identified, you can check their certificates in the FAA airman registry the same way I pull a CDL status.

Age is the first line in both rulebooks. A driver must be 21 to operate a commercial motor vehicle in interstate commerce under 49 CFR 391.11, and most states let 18- to 20-year-olds drive only within state lines, usually with tighter hazmat limits. Aviation builds a ladder instead. A pilot can solo an airplane at 16, earn a private certificate at 17 and a commercial certificate, the license to be paid to fly, at 18. The airline transport pilot certificate a Part 135 captain on a passenger jet needs requires age 23 and 1,500 hours under 14 CFR 61.153 and 61.159. A restricted version is available at 21 under the rules Congress ordered after the 2009 Colgan Air crash, and it was built to put first officers in airline cockpits, not captains. Put the two side by side and a 20-year-old commercial pilot can legally fly for hire in some jobs at an age when federal rules won’t let a 20-year-old haul a load from Florida into Georgia. That 20-year-old can’t captain a charter jet full of paying passengers.

Hours of service come next. A truck driver gets 11 hours of driving inside a 14-hour window after 10 hours off duty, with a 30-minute break after eight hours of driving and a 60- or 70-hour weekly cap under 49 CFR Part 395, all recorded on an electronic logging device. A two-pilot charter crew on an unscheduled trip is limited to 10 hours of flight time in any 24 consecutive hours and must have at least 10 consecutive hours of rest in the 24 hours before the assignment ends under 14 CFR 135.267. This crew had been airborne a little over two hours, so the flight time itself isn’t the issue. The question investigators ask is the one I ask on every fatigue case: what the crew did in the 72 hours before departure, whether they flew in the day before, where they slept and how long they had been on duty before wheels up.

Drug and alcohol testing runs on nearly identical clocks. Under FMCSA’s rule at 49 CFR 382.303 and the FAA’s at 14 CFR Part 120, a post-accident alcohol test must happen within eight hours and a drug test within 32. When the crew dies, there is no collection to run, so toxicology moves to the medical examiner and the FAA’s forensic toxicology laboratory. The history before the crash lives in the operator’s random testing records and, for pilots, in the FAA’s Pilot Records Database under 14 CFR Part 111, the aviation cousin of the FMCSA Drug and Alcohol Clearinghouse.

Medical qualification works the same way with different paperwork. A CDL driver carries a medical examiner’s certificate good for up to 24 months from an examiner on the FMCSA National Registry under 49 CFR 391.41 through 391.49. A professional pilot carries a first- or second-class FAA medical certificate from an aviation medical examiner, renewed on a shorter cycle depending on age and class. Investigators will pull both pilots’ medical applications, which require disclosure of conditions and medications, the same way I pull a driver’s long-form physical.

Training and checking are stricter in aviation than in trucking, and I want those records first. A Part 135 pilot must pass a competency check every 12 months under 14 CFR 135.293. The captain must pass an instrument proficiency check every six months to fly under instrument rules under 135.297, plus an annual line check with a check pilot under 135.299. Trucking has nothing like a recurring check ride. On this crash, the training records that matter most are upset recognition and recovery, high-altitude weather, ice crystal icing and unreliable airspeed procedures.

Then the machine. On a truck, I pull the Part 396 file: the systematic inspection and maintenance program, the annual inspection, the driver vehicle inspection reports, brake and tire records and open recalls. On a jet it’s the maintenance logs under 14 CFR 91.417, the inspection program the operator follows under 14 CFR 135.411 and the manufacturer’s schedule, the status of every applicable airworthiness directive under 14 CFR Part 39, and the records on the pitot-static and air data system, the autopilot and Mach trim, and the weather radar. That radar isn’t optional on this kind of flight. Federal charter rules require approved airborne weather radar on large transport category airplanes carrying passengers and bar starting an instrument flight when thunderstorms may reasonably be expected along the route unless that radar is working, under 14 CFR 135.175. The trucking parallel is 49 CFR 392.14, which requires extreme caution in hazardous conditions and requires a driver to stop when conditions become dangerous enough. In both worlds, the weather rule is written around judgment, and judgment is the hardest thing in the file to reconstruct.

The claims side runs in parallel. In trucking, the carrier’s insurer has adjusters and defense counsel moving within hours, and the first fight is over preserving the electronic data. In aviation, the underwriter on the hull and liability policy moves just as fast, but the NTSB controls the wreckage and the party process restricts what the companies involved can release while the investigation runs. The rule I give clients holds in both worlds: the paper written before the crash is worth more than any statement given after it.

One last piece of math, because a lot of people say this weekend that flying private is safer than driving. It depends on what you count. In absolute numbers, trucks win the grim contest easily: crashes involving large trucks killed 5,340 people in 2024, according to the National Highway Traffic Safety Administration. Per mile, drivers of those trucks are among the safest on the road, with an occupant fatality rate of 0.28 per 100 million miles in 2024 compared with 1.05 for passenger cars. Per hour of exposure, the picture flips for charter flying. The overall traffic fatality rate was 1.10 deaths per 100 million vehicle miles in 2025, which at an average 35 mph works out to roughly 0.04 deaths per 100,000 hours on the road. On-demand Part 135 charter flying ran 0.319 fatal accidents per 100,000 flight hours in 2019, the worst year in a decade for that sector. Airlines are the safest way to travel. Charter jets are not safer than driving, hour for hour.

The math explains the crater. It explains why there’s no airplane on Military Trail and why the investigators will spend weeks on their knees in a hole instead of walking around a wreck. It doesn’t explain why a jet that crossed the Gulf of Mexico at 35,000 feet ended up inside a storm cell a few miles from its destination’s coastline. That’s what matters to nine families, and only the investigation can answer it.

Worksheet

Descent: 35,250 ft (17:48:07Z) to 31,350 ft (17:48:39Z) = 3,900 ft / 32 s ≈ 7,300 fpm. 31,350 ft to 8,750 ft (17:49:23Z) = 22,600 ft / 44 s ≈ 30,800 fpm ≈ 514 ft/s. Total 26,500 ft / 76 s ≈ 349 ft/s (FAA: ~350 ft/s).

Speed at 10,125 ft: GS 298 kt = 503 ft/s; VS 30,976 fpm = 516 ft/s; resultant √(503² + 516²) ≈ 721 ft/s ≈ 491 mph ≈ 219.6 m/s; path angle atan(516/503) ≈ 46°.

Mass (estimate): BOW 14,772 lb + ~1,600 lb pax/bags ≈ 16,400 lb ZFW; fuel remaining est. 2,000 to 2,500 lb = ~18,500 lb (8,400 kg). MTOW 23,500; MZFW 17,000.

Kinetic energy: ½ × 8,400 × 219.6² ≈ 202.5 MJ ≈ 48 kg (107 lb) TNT at 4.184 MJ/kg. Sensitivity: 400 mph ≈ 134 MJ; 550 mph ≈ 254 MJ.

Truck: 80,000 lb (36,287 kg) at 65 mph (29.06 m/s): ½ × 36,287 × 29.06² ≈ 15.3 MJ. Ratio ≈ 13.2.

Car: 4,000 lb (1,814 kg) at 60 mph (26.82 m/s) ≈ 0.65 MJ. Ratio ≈ 310.

Momentum: jet 8,400 × 219.6 ≈ 1.84 × 10⁶ kg·m/s; truck 36,287 × 29.06 ≈ 1.05 × 10⁶; ratio ≈ 1.75.

Crush duration: 17.9 m / 219.6 m/s ≈ 0.08 s. Average force: (8,400 / 17.9) × 219.6² ≈ 22.6 MN ≈ 5.1 million lbf.

Deceleration: v²/2d: d = 5 m = ≈ 4,820 m/s² ≈ 490 g; d = 3 m = ≈ 8,040 m/s² ≈ 820 g.

Fuel energy: 2,300 lb = 1,043 kg × 43 MJ/kg ≈ 44,900 MJ ≈ 220 × KE.

Exposure comparison: 1.10 deaths / 100M VMT ÷ (100M mi / 35 mph = 2.86M hr) ≈ 0.038 deaths per 100,000 vehicle-hours.

The aviation figure is fatal accidents per hour; the road figure is deaths per hour; units differ, direction holds.

Before we start with “This is so long,” this is an insurance guide. A comprehensive guide to every reason why the trucking crisis lives and breathes from an insurance perspective. It’s a guide, not an article.

The call goes about the same way every time. A family gets hit by a tractor-trailer. The truck has a DOT number on the door and an insurance filing on record with the federal government. A claims adjuster calls back a week later and says the tractor isn’t scheduled on the policy, the driver isn’t listed and the company never added either one, so there’s nothing to pay. Most people hang up believing that’s the end of it.

For an interstate for-hire motor carrier, it isn’t. Federal law put a one-page endorsement on that policy for exactly this situation. It’s called the MCS-90, and it says the insurer pays a final judgment for the carrier’s negligence whether or not the vehicle was ever described in the policy. The insurer can then go after its own customer for the money. It can’t walk away from the person the truck hit.

The MCS-90 is the most important document in trucking insurance and the least understood, including by some of the people adjusting the claims. This piece breaks it down, then follows the money through the $750,000 floor Congress set when Jimmy Carter was president, the shift from real underwriting to instant online policies, the state assigned risk plans that put carriers back on the road after every insurer in the voluntary market said no, the fleets that declare one truck and run hundreds, the insurers suing their own customers for fraud, a hotshot run out of an Airbnb that killed a man on an interstate, the risk retention groups with no safety net, and the bill that lands on everyone else.

The summary

The MCS-90 is a federal guarantee, not a coverage grant. If an interstate carrier is found negligent and a court enters a judgment, the insurer that filed the carrier’s federal proof of insurance must pay that judgment up to the federal minimum, usually $750,000, even if the truck or driver was never on the policy and even if the carrier lied on its application. The insurer then has the right to be reimbursed by the carrier. It rarely collects, because the carriers most likely to trigger an MCS-90 are the ones built to disappear. The $750,000 floor hasn’t moved since 1980. Underwriting has moved from inspection to self-declaration. When the voluntary market does say no, most states run an assigned risk plan that writes the carrier anyway and spreads the losses across every company selling auto insurance in that state. Every one of those paths ends in the same place: unrecovered losses priced into the premiums of honest carriers, shippers and consumers.

1. What the MCS-90 is

The Motor Carrier Act of 1980 deregulated trucking and, in the same bill, required interstate carriers to prove they could pay for the harm they caused. The Federal Motor Carrier Safety Administration carries out that requirement in 49 CFR Part 387. A for-hire carrier hauling property across state lines in vehicles over 10,001 pounds must show financial responsibility in one of three ways: an MCS-90 endorsement on a liability policy, an MCS-82 surety bond, or FMCSA-approved self-insurance. Nearly every carrier uses the MCS-90. The insurer files a Form BMC-91X with FMCSA, and that filing is what activates the carrier’s operating authority.

The endorsement wording is fixed by regulation at 49 CFR 387.15 and can’t be edited by the insurer. It still refers to the Interstate Commerce Commission, an agency abolished in 1995. The operative promise is that the insurer agrees to pay, within the limits described, any final judgment recovered against the insured for public liability resulting from negligence in the operation, maintenance or use of motor vehicles subject to the federal requirements, “regardless of whether or not each motor vehicle is specifically described in the policy.” The same paragraph says that promise holds whether or not the negligence happens on a route or in a territory the carrier is authorized to serve.

The next clause shuts the door on most denials. The endorsement says no condition, provision, stipulation or limitation in the policy, in the endorsement or in any other endorsement, and no violation of them, relieves the insurer of liability or of paying a final judgment. It also says the obligation applies irrespective of the insured’s financial condition, insolvency or bankruptcy. Late notice, failure to cooperate, an unlisted tractor, an excluded driver, a false application: those can be fights between the insurer and its customer. They aren’t defenses against the injured member of the public, up to the federal minimum.

The last piece explains everything that follows. The endorsement says the insured agrees to reimburse the insurer for any payment it made that it wouldn’t have been obligated to make under the policy except for the MCS-90. The insurer pays the victim, then bills the carrier. Most people in the business call that subrogation. Technically it’s a contractual reimbursement right. Either way, the insurer has to collect, not the victim.

Courts have spent 40 years defining the edges. The majority view, adopted by the Tenth Circuit sitting en banc in Carolina Casualty Insurance Co. v. Yeates in 2009, treats the MCS-90 as a surety obligation rather than a rewrite of the policy. Under Yeates, the endorsement is triggered only when the attached policy doesn’t otherwise cover the loss and no other insurer is available to satisfy the federal minimum. The court called it a safety net that protects the public when other insurance coverage is lacking. The MCS-90 isn’t extra insurance. It’s the floor under the floor.

It covers public liability, meaning bodily injury, death, property damage and certain environmental restoration owed to third parties. It doesn’t cover cargo or the carrier’s own employees. It pays only up to the federal minimum for the vehicle and cargo type, not the policy limit and not the full value of a catastrophic case. Some courts have held it applies only when the truck was operating in interstate commerce at the time of the crash. It pays a final judgment, not a demand letter, which is why so many victims are told no. A claims department can take a coverage position before there’s a judgment. The MCS-90 obligation attaches when the judgment is entered.

2. “The truck wasn’t on the policy”

When an adjuster says the tractor or driver wasn’t on the policy, they’re usually describing the policy’s coverage, and they may be right. Many small-fleet trucking policies cover only “scheduled autos,” the specific units listed on the declarations page. A carrier that runs a tractor it never added, or puts a driver behind the wheel the insurer excluded, has breached its own contract.

That’s a problem between the carrier and the insurer. For the person the truck hit, it’s the situation the MCS-90 was written for. Courts have described the endorsement as making the insurer liable to third parties for the insured’s negligent use of any motor vehicle, even one not covered under the policy. The federal government didn’t create that obligation to protect insurers or carriers. It created it so a crash victim isn’t left holding a judgment against a company with no assets.

If you or a client get that call, follow this order. Get the carrier’s USDOT and MC numbers from the crash report or the truck door. Pull the carrier’s insurance history from FMCSA’s Licensing and Insurance system, which shows the insurer that filed the BMC-91X, the policy number, the coverage amount and the effective and cancellation dates. Check whether that filing was in force on the date of the crash. An MCS-90 can only be canceled with 35 days’ written notice to the insured and 30 days’ notice to FMCSA, so a policy “canceled” the week before a wreck often wasn’t canceled yet under federal law. Ask the insurer in writing for the full policy, including the MCS-90. Hire a lawyer who handles trucking cases, because the MCS-90 pays judgments, and judgments come from litigation. Then look past the carrier. After the Supreme Court’s decision in Montgomery v. Caribe Transport II in May 2026, the broker who picked that carrier may be on the hook too.

A carrier operating on someone else’s authority, the lease-on model, puts the lessee carrier’s insurer and its MCS-90 in play. If the crash involved more than one policy or more than one insurer, courts following Yeates look at the regular coverage first and the MCS-90 last.

3. The $750,000 floor nobody will raise

President Carter signed the Motor Carrier Act on July 1, 1980. Congress set the minimum at $750,000 per accident for general freight and higher amounts for oil and hazardous materials, and gave the Secretary of Transportation authority to raise the numbers. The Department phased the requirement in over about five years, which is why some reports, including some of mine, date the floor to the Reagan administration. Today the schedule at 49 CFR 387.9 still reads $750,000 for general freight, $1 million for oil and certain hazardous materials, and $5 million for the most dangerous hazmat loads. A one-truck owner-operator and a 500-truck fleet carry the same federal minimum. There’s no sliding scale for revenue, miles or fleet size, and no year-end audit that reconciles exposure the way workers’ compensation does.

Nobody has used the authority to raise it. In April 2014, FMCSA sent Congress a report concluding the $750,000 limit doesn’t adequately cover catastrophic crashes, chiefly because of inflation and medical costs. In November 2014, the agency published an advance notice of proposed rulemaking. On June 5, 2017, it withdrew that notice, saying commenters hadn’t given it enough data for the cost-benefit analysis a rule would require. The Owner-Operator Independent Drivers Association, the American Trucking Associations and more than 60 trade groups have opposed increases, arguing that about 98% of claims settle within current limits. The Truck Safety Coalition, trial lawyers and the Trucking Alliance pushed for one. The Trucking Alliance has recommended $2.9 million, the 1980 figure adjusted for general inflation, with medical-cost indexing after that. New Jersey didn’t wait. In July 2024, it raised its own minimum for trucks over 26,001 pounds to $1.5 million.

Adjusted by CPI from 1980, $750,000 is roughly $2.8 million today. Adjusted for medical inflation, it’s closer to $5 million. Minimums aren’t written for the 98% of claims that settle. They’re written for the crash that kills four men on a state highway on a Tuesday afternoon. The American Transportation Research Institute put the median nuclear verdict in trucking at $36 million in 2022 and the average trucking verdict between 2020 and 2023 at $27.5 million. The federal floor covers about 2% of that median. AM Best reports that average commercial auto liability claim severity has more than doubled over the past nine years.

The number also decides whether anyone underwrites. A full risk control assessment on a small carrier runs $3,000 to $6,000 the traditional way. The premium on a minimum-limit policy for that carrier might be $8,000 to $15,000. At that ratio, insurers skip assessment and focus on volume. The Truck Safety Coalition, citing FMCSA’s 2014 review, argued the minimums should be set high enough “to give the insurance companies a reason to set realistic underwriting standards.” Congress built deregulation on the theory that insurers would police the carriers they wrote. A limit priced for 1980 doesn’t pay them to.

4. How insurance stopped being the gate

You can get operating authority for $300. You can get a USDOT number for free, file a process-agent designation for pocket change, rent a tractor for about $1,000 a week, and fake a driver qualification file. For most of my career, the one thing you couldn’t fake was insurance. I’ve explained it for years with the influencer economy. Influencers can rent a Bentley for the afternoon and book a mansion for one night of pictures. They can’t rent a Gulfstream for the photo shoot. The jet is real, or it isn’t. Insurance was our jet.

Getting that coverage meant sitting across from an agent and an underwriter who wanted loss runs, a driver list with MVRs, a vehicle schedule with VINs, years of experience, sometimes a site visit, and a premium that reflected it all. The best fleets in the country still buy coverage that way. They’re in group captives, member-owned insurance companies where risk control professionals review driver files, maintenance programs and telematics before anyone gets in. If a member’s losses climb, consultants show up. If the member doesn’t improve, it’s removed. When losses stay low, the underwriting profit comes back to the members. Nobody in a captive has to be told the front end matters, because it shows up on the distribution statement every year.

The bottom of the market went the other way about a decade ago. Commercial auto writers built online quoting and binding for small fleets and new authorities. GEICO entered commercial trucking with a program marketed “for the little guy,” advertising “quick purchase” options and “an instant price and coverage within minutes.” Progressive has run a similar online model for years. An applicant answers questions about who they are, what they haul, how many trucks they run and who drives them, and can walk away with a bound policy and a BMC-91X on file with FMCSA the same day. Algorithms score the answers against MVR data, credit-based variables and the carrier’s thin federal record. Nobody visits the yard. Nobody counts the tractors.

Self-declaration is the core problem. The applicant tells the insurer how many power units it operates. The applicant tells FMCSA how many power units it operates on the MCS-150. Both numbers are taken largely on trust, and the premium is priced off the declared fleet. An operator who declares one truck pays for one truck. If that operator then runs 200 tractors under the DOT number, the MCS-90 still guarantees the public up to $750,000 per accident on each one. The insurer collects premium on one unit and carries federal exposure on all of them. Insurers answer with audits, mid-term endorsements, mileage reconciliation and the right to cancel, and all of those happen after the fact. A cancellation needs 35 days. An audit happens at renewal. A fleet that cycles to a new LLC every 60 to 90 days is gone before the audit runs.

THE TEA analysis of 2.8 million insurer-carrier relationships in FMCSA filing data shows where that leaves the risk. When carriers are ranked by the riskiness of their insurer’s portfolio, the top 5% account for 31.9% of all crashes and 31.8% of fatal crashes. The top 25% account for 70.1% of both. The 50 largest insurers cover 55.2% of carriers and 27.7% of crashes. The remaining 3,680 smaller insurers, the segment where surplus lines, specialty programs and residual market placements sit, cover 44.8% of carriers and 72.3% of crashes. Thirteen insurers each write at least 500 carriers, with half or more of their book in the high- or critical-risk tiers. Ten insurers account for 50.25% of all new-entrant carriers.

No federal or state law requires an insurer to look at any of that before it binds a policy. FMCSA checks that a BMC-91X is on file. Under the McCarran-Ferguson Act of 1945, insurance regulation belongs to the states, and state insurance departments regulate solvency, licensing, rates and claims practices, not whether an underwriter reviewed a carrier’s crash history before writing it. Both the captive and the instant-issue policy are legal, and the regulatory framework treats them the same.

5. When every insurer says no, the state says yes

A carrier that burns through the standard markets and the subprime markets has one more door. Most states run a residual market for auto insurance, the assigned risk plan, and AIPSO, the Automobile Insurance Plans Service Office, is the industry association that manages it. AIPSO says it serves as Plan Manager for residual market mechanisms in 37 states and the District of Columbia. On the commercial side the mechanism is called the Commercial Automobile Insurance Procedure, or CAIP. A trucking company that can show it was turned down in the voluntary market applies to the state plan through a certified producer, and the plan has to write it.

The mechanics matter for everyone else. A CAIP policy is issued by a servicing carrier, an insurer under contract to the plan that writes, bills and adjusts the business on behalf of every company that sells auto insurance in the state. The premiums, expenses and losses go back into the plan and get split among those member companies by their share of the state’s voluntary market. The standard plan endorsement says it in one sentence: the policy is “written and handled by a carrier representing all carriers” through the plan. The insurer whose name is on the BMC-91X didn’t choose the risk. The companies paying the losses never saw the file. The more good business an insurer writes in a state, the bigger its share of the carriers nobody wanted.

Plan rates run higher than the voluntary market, and they still don’t cover the losses of the worst risks, because the rate structures were built for a small residual population: a contractor non-renewed over a fender bender, a local delivery company that had a bad year. They weren’t built for 80,000-pound trucks with crash histories and nuclear verdict exposure. The insurer has no discretion to decline. A carrier with a conditional rating, an out-of-service rate double the national average and a stack of enforcement cases gets a policy, gets its BMC-91X filed, and FMCSA activates its authority. The MCS-90 rides on that plan policy like any other.

For years, one of the biggest commercial servicing carriers has been National Continental Insurance Company, a Progressive subsidiary. A New York Department of Financial Services examination says the company began acting primarily as a servicing carrier for commercial auto insurance plans and special risk distribution plans in selected states in 1996, before building a voluntary commercial book. Effective Sept. 1, 2022, National Specialty Insurance Company, a Markel company serviced by AIPSO, replaced National Continental as the CAIP servicing carrier in California, New Jersey, Idaho, New Mexico and other plans, and National Continental’s existing plan policies were set to non-renew on their next anniversary. A few plans have started asking the question every underwriter used to ask. Since Sept. 1, 2019, California’s plan has required a CAIP Inspected Units Form with any commercial application for a risk that needs a federal filing, and New Jersey and the Western plans now publish the same kind of form.

The system has been gamed before. In 1992, the New Jersey Automobile Insurance Plan went to federal court over fraud in the New Jersey and Pennsylvania commercial auto plans, where intermediaries had worked the plan rules to win large premium reductions for trucking companies and shift the losses to the assigned insurers. When New Jersey doubled its own minimum in 2024, carriers that couldn’t afford $1.5 million in the voluntary market moved into the New Jersey plan. Meanwhile, the voluntary market keeps shrinking. Chubb pulled back from commercial trucking in Chicago, Nationwide exited its primary E&S commercial auto business in 2023, and AmTrust and Wesco reportedly followed. An insurer that writes no voluntary commercial auto in a state has no share of that state’s plan losses, so leaving is the only way out of the pool, and every exit concentrates the plan’s losses on the companies that stay.

The plan wasn’t designed as a dumping ground. It becomes one when the voluntary market has no obligation to screen and the plan has no point at which a carrier is too dangerous to write. Any reform that adds underwriting standards to the voluntary market pushes the rejects here first, which is why the plan has to be part of the fix.

6. Gold Coast: a plan policy on I-10

On the afternoon of April 15, 2023, a tractor-trailer hauling Ghost Energy drinks for Anheuser-Busch ran into slowed traffic in a construction zone on eastbound Interstate 10 near Beaumont, Texas, with workers on the job. Ten vehicles were involved. Brandon Rogers was killed and 16 other people were hurt. The Texas crash report notes that a bus dashcam showed the truck never braked before the first impact. Jefferson County indicted the driver, Leandre Sime, on June 7, 2023. The truck was dispatched under USDOT 2190975, DMG Consulting & Development Inc., doing business as Goldcoast Logistics Group of Elgin, Illinois. The load came to Gold Coast the day before, through the broker Archerhub, after the original carrier failed to show.

Gold Coast wasn’t a small operation. Its last MCS-150, filed Sept. 29, 2022, reported 350 term-leased tractors, 334 drivers and 46 million miles in 2021. It also wasn’t a secret. On May 17, 2022, FMCSA closed an enforcement case against the carrier with a $791,640 settlement for violations that included knowingly allowing a driver to operate without a valid CDL and violating hours-of-service driving limits. THE TEA analysis of FMCSA’s closed enforcement data ranks that as the largest settled amount among 11,946 closed cases. FMCSA’s crash file lists 44 Gold Coast crashes in calendar 2022 alone.

The carrier’s federal insurance filings trace the descent I’ve described in this series. Artisan & Truckers Casualty, a Progressive company, filed its proof of coverage from 2011 into 2015. Old Republic Insurance Co. took it from October 2015 to October 2017. American Inter-Fidelity Exchange filed next, and that filing was canceled May 30, 2018. That same day, National Continental filed on policy CIL0004950657, and the same base number renewed every May 30 after that: 2018, 2019, 2020, 2021, and 2022. The 2022 renewal took effect 13 days after the $791,640 settlement. The federal filing was canceled and refiled several times, most recently effective Jan. 6, 2023, 99 days before the crash. National Continental canceled it effective May 30, 2023, 45 days after Brandon Rogers died. FMCSA rated the carrier unsatisfactory and ordered it out of service on Aug. 27, 2023, and issued a second order for an unpaid fine on Sept. 12. A second enforcement case closed Oct. 19, 2023, for $97,990, which brought Gold Coast’s settled federal penalties to $889,630, the highest carrier-level total among 11,307 carriers in the same analysis.

The policy in force on April 15, 2023, wasn’t voluntarily placed. Every endorsement in the 49-page policy carries the same instruction: that it must be attached to policies issued in accordance with the Illinois Automobile Insurance Plan. Stapled into it is form AP 9007, the Commercial Automobile Insurance Procedure Mandatory Endorsement, edition June 1982, printed when the Interstate Commerce Commission still regulated trucking. The plan name line was left blank. The amended declarations, dated Nov. 24, 2022, and mailed Jan. 6, 2023, show policy CIL 000-4950-657-2, a policy period of May 30, 2022, to May 30, 2023, a $1 million combined single limit, covered auto symbol 1, “any auto,” a producer in Waverly, Iowa, and a liability premium rated on cost of hire with a tentative rate subject to a test audit within 60 days. The named insured’s business is listed as “1 TRUCKER DOT#2190975.” The form of business is listed as a partnership. DMG Consulting & Development is a corporation.

The family’s lawsuit, Cause No. 23DCCV0514 in the 60th District Court of Jefferson County, names the carrier, Anheuser-Busch, Archerhub, Ryder, Sime, Gold Coast’s owner Dragos Sprinceana and others. The petition alleges Sprinceana is the carrier’s alter ego and moved assets to avoid paying for the crash. Those are allegations; the defendants deny them and no court has ruled on them. I’m a retained expert for the plaintiffs in that case.

Put the MCS-90 and the plan side by side. A carrier with a $791,640 federal penalty and 44 crashes in a year couldn’t stay in the voluntary market. The state plan wrote it anyway, as required by law. The plan’s servicing carrier filed the federal proof that kept its authority active. If a judgment comes, the MCS-90 guarantees the public up to the federal minimum and the policy pays up to $1 million. Under the plan’s design, every company writing auto insurance in Illinois funds its share of that loss. The carrier has been out of service for three years.

7. One declared truck, hundreds on the road

Gold Coast declared 350 tractors and ran 350 tractors. The bigger problem at the bottom of the market is the carrier that declares one.

Danielle Chaffin put out another wild group, MLTZX Group LLC, USDOT 5233773, registered Sept. 2, 2026, at an apartment in Murphysboro, Illinois. Its MCS-150 declares one power unit and one driver. Its insurance filing is a $1 million BIPD policy from Artisan & Truckers Casualty Co., effective Sept. 21, 2026. Between Sept. 28 and Oct. 29, inspectors logged 323 inspections on 285 different VINs carrying 286 different plates in 41 states. On Oct. 28 alone, its “one truck” was inspected in 10 states.

FMCSA’s census lists MLTZX Group LLC’s only officer as Andrey Vorobyev, at 1822 Edith St. #4, Murphysboro, Illinois. Variants of the name appear in Tea Technologies sanctions databases as Andrey Viktorovich Vorobev July 24, 1985OFAC (Russia EO 14024), UK, Canada, Australia, Switzerland, Japan Member of Russia’s parliament, the State Duma Andrey Yuryevich Vorobyev/VorobyovApril 14, 1970OFAC (Russia EO 14024), UK, Canada, Australia, Switzerland Governor of the Moscow Region Andrei Vorobiev June 18, 1966 Crime/watchlist data. No program, address, or notes in our copy.

MLTZX is the newest of 17 LLCs that have handed the same pool of hotshot pickups from authority to authority since October 2025. Together, those 17 declared 79 trucks to FMCSA. Together they logged 6,291 inspections on 3,096 different VINs in 49 states, with 56 crashes, 30 people injured and 2 killed. Every link carried a federal insurance filing, most from Progressive group companies and GEICO Marine. One link, Golla Group LLC, kept getting inspected for four months after FMCSA issued a federal out-of-service order against it. The broader network I’ve mapped is larger: 32 connected companies declaring 32 trucks while running roughly 7,200 VINs across about 10,000 plates, many of them expired temporary tags. Earlier this year I reported two GEICO-insured hotshot carriers claiming three trucks between them with 1,800 inspections across 11 VINs in two years, and seven more clusters like it, mostly Eastern European hotshot operators based in Illinois.

Every one of those 3,096 VINs, operating under a DOT number with a filed policy, carries a federal guarantee of up to $750,000 to the people it hits. The premium behind it was priced for 79 trucks. When a crash on an unlisted unit goes to judgment, the insurer pays. Then it has a reimbursement right against an LLC that was registered at an apartment, declared one truck, and went dark when the next LLC came online. It probably won’t collect.

8. When the insurer is the one getting played

The court filings on the Super Ego network show what this looks like from the insurer’s side.

On Sept. 11, 2020, American Inter-Fidelity Exchange sued in the Northern District of Illinois, Case No. 1:20-cv-05394, asking a federal judge to rescind a physical damage policy it issued to Aleksandar Mimic. AIFE alleged four material misrepresentations on the application, including that he answered “no” when asked whether he’d operated under another name, when AIFE alleged he’d operated under Windy City Trans, Rex Trucking, Super Ego Holding, Kordun Express, Floyd and Time Logistics. The equipment schedule in that application listed more than 100 tractors. Seventy-three days later, AIFE voluntarily dismissed the case with prejudice. No court ruled on the allegations.

On Feb. 3, 2023, The North River Insurance Co., a Crum & Forster company, sued Super Ego Holding LLC and United Ego LLC in DuPage County, Case No. 2023LA000108, for statutory insurance fraud under 720 ILCS 5/17-10.5, common-law fraud and a declaration that four commercial auto policies are void. North River alleges the defendants activated coverage on previously uninsured trucks and trailers after the date of loss but before reporting the loss, submitted inflated repair and towing amounts, and submitted claims after repairs were supposedly done without adequate evidence that the damage existed. Super Ego and United Ego deny the allegations and counter-sued, claiming at least $4,234,340, built largely on premiums North River collected before voiding the policies. On Feb. 11, 2026, the parties entered an agreed order in which the defendants waived their lost revenue, lost business and lost profit claims and confirmed they can’t identify anyone beyond the people already named who submitted claims or maintained the insured equipment list. The case is active, and every allegation on both sides remains an allegation.

MS Amlin and Lloyd’s Syndicate 2001 sued Floyd Inc. in the Northern District of Illinois, Case No. 1:23-cv-03253, to rescind a cargo policy. That case settled in August 2024. In an April 7, 2025, deposition in Austin v. Floyd Inc., Aleksandar Mimic testified that he is CEO of both Floyd and Super Ego Holding and that Super Ego Holding holds no operating authority. The excerpts were filed publicly in that case on July 7, 2025.

The federal filings of one network carrier show the whole insurance ladder. Rocket Expediting LLC, USDOT 2356464 of Columbus, Ohio, is a defendant with Super Ego Holding, Mimic and Floyd in Rice v. Super Ego Holding LLC, a truth-in-leasing case filed Jan. 23, 2026, in the Northern District of Ohio, No. 5:26-cv-00186. OOIDA’s risk retention group filed Rocket’s liability coverage from 2012 to November 2020. Progressive Casualty took it next. On Oct. 23, 2021, National Continental, Progressive’s plan servicing company, filed on policy COH0006255974. Progressive Preferred filed on Oct. 22, 2022, and canceled that filing effective Dec. 13, 2022. The next day, National Specialty filed on policy CAR3400000080. Prime Insurance Co. followed in December 2023, National Specialty again from March 2024 to March 2025, then Progressive Preferred, Concert Specialty and Trisura Specialty, whose filing was canceled Nov. 1, 2025. That’s eight different insurers since 2020, and three separate stretches on paper from the two companies that service the assigned risk plans.

When an insurer believes a carrier gamed what was on the policy, its remedies are rescission, a fraud suit or walking away. None of those touch the federal guarantee to a member of the public hurt by an unlisted truck. The insurer pays that, then litigates for years with its own customer, often against a structure built so there’s little left to recover. The network’s map also includes an insurance agency, Millennium Insurance Group LLC, the renamed Super Ego Insurance Agency, sitting alongside the carriers.

9. Who pays when the carrier is an Airbnb

On a February night, a one-ton pickup pulling a wedge car-hauler loaded with two new heavy-duty pickups ran out of fuel in the middle lane of a Midwest interstate. The right shoulder was clear, and the driver had enough rolling speed to coast onto it. He stopped in a live lane of 65 mph traffic after dark instead, set out three reflective triangles in a pattern the regulation doesn’t recognize, and taped consumer flashlights to the tailgate of the rearmost pickup on the trailer. A man in his 60s, driving a Sprinter van that night for a small expediting company, came down that lane at highway speed and hit the back of the trailer. He died at the hospital about 90 minutes later.

The pickup’s driver held no U.S. commercial license of any class. He held a Russian CDL. The manufacturer’s combined weight rating for that truck and trailer requires a Class A CDL in every factory configuration. He needed a translation app to answer the trooper’s questions, and 49 CFR 391.11(b)(2) requires a driver to respond to official inquiries in English. He didn’t know the truck had run out of fuel until the trooper had him turn the key and look at the gauge. He got a U.S. CDL about three months after the crash.

The load changed hands four times before it reached him. A national shipper tendered the new vehicles to a haulaway carrier with more than 60 years in business and a contract that made it responsible for every subcontractor it used. That carrier brokered the load to a one-truck carrier whose insurance schedule listed nothing but over-the-road tractors. Seventeen days before the crash, that one-truck carrier had been placed out of service for operating a commercial vehicle without a CDL, and its driver out-of-service rate was nearly seven times the national average. The next morning, the haulaway carrier’s desk assigned it 11 more loads. It had no broker authority, and it re-brokered the load to a company that existed only on the bill of lading. The truck was titled to a shell whose owner had left the country 16 months earlier and was run day to day by a company that had never held motor carrier authority, operating under an assumed name with its principal place of business listed at an Airbnb unit in a Miami high-rise. I’m a retained expert in that case, and the parties stay unnamed here.

Run the payers in order. The company running the truck had no authority, no BMC-91X and no MCS-90 behind it, and any personal policy on a pickup excludes for-hire hauling. The one-truck carrier’s policy scheduled only tractors, so its insurer has the “not on the policy” answer from Section 2 ready. If a court decides the carrier was the motor carrier responsible for the move, its MCS-90 can still respond up to $750,000 after a judgment, and its insurer then chases the one-truck company for reimbursement. If the court finds it acted only as an unlicensed broker, the endorsement may not apply to the loss at all. The haulaway carrier signed a contract making it responsible for its subcontractors, carries its own liability and hired auto coverage, and now faces a negligent selection claim after Montgomery. Its brokerage director testified that the desk had no written vetting policy. It’s the only company in the chain with a balance sheet, so the claim goes there first.

Then the bill moves to the victim’s side. If he was an employee, his employer’s workers’ compensation insurer owes death benefits under state law and holds a lien on any recovery from the trucking side. Depending on the van’s coverage, an uninsured or underinsured motorist policy may respond. His health insurer, Medicare or Medicaid paid the hospital and files its own lien. Each of those payers prices the loss into somebody else’s premium: the expediting company’s workers’ comp rates, the haulaway carrier’s renewal, the auto policies in that state. The shell, the company at the Airbnb address and the man who dispatched the truck have nothing anyone can collect.

10. Risk retention groups: the market with no net

When admitted insurers get burned, they raise rates, tighten underwriting or leave. When enough leave a market, some business flows to risk retention groups. A risk retention group is a liability insurer owned by its policyholders, authorized by the federal Liability Risk Retention Act of 1986, licensed in one domicile state and largely exempt from regulation in the other 49. Under 15 U.S.C. 3902(a)(2), it can’t participate in any state insurance guaranty fund. Every RRG policy has to carry a notice saying guaranty fund protection isn’t available. Vermont alone houses 85 licensed RRGs that wrote $2.92 billion in gross premiums in 2023.

The structure isn’t the problem. OOIDA’s RRG has served owner-operators for about 25 years, and ATTIC RRG insures large, safety-focused fleets running more than 7,000 trucks. The distressed end of the market works the other way. It forms because its members can’t get coverage anywhere else, and a management company often runs it and gets paid on premium volume, not loss results. In THE TEA’s study of 314,078 interstate for-hire carriers, RRG-insured carriers scored 4.6 to 11.6 points worse than underwritten peers of the same fleet size, with a dirty inspection rate- inspections with violations in more than one BASIC category- of 50.71%, more than 15 points above the underwritten average.

When one of those fails, a crash victim’s judgment becomes a claim against a receivership. Federal Motor Carriers RRG was liquidated in 2011. Its operator later formed Spirit Commercial Auto RRG, which a Nevada court put into permanent receivership on Feb. 27, 2019, with $199 million in unpaid losses. James D. Richardson, hurt in a crash at 53rd and Western in Chicago, settled with a Spirit-insured carrier for $1 million and couldn’t collect from the guaranty funds in Nevada or Illinois. A Vermont court liquidated Global Hawk Insurance Company RRG on June 8, 2020, leaving 1,008 commercial trucks “effectively uninsured.” The liquidator found 512 policies that never made it onto the company’s books, and its president, Jasbir Thandi, pleaded guilty to insurance fraud conspiracy after moving roughly $14 million out of the company. Six years later, 2,748 carriers still show a Global Hawk filing of record in FMCSA’s system, 131 of them with active census records. Across the market, 76 RRGs insure 29,423 motor carriers with 209,854 crashes and 6,373 fatal crashes in the federal crash file, all outside guaranty fund protection.

The MCS-90 rides on an RRG policy like any other. It’s only as good as the company that signed it.

11. Who pays

Fewer balance sheets back trucking insurance than the certificate names suggest. Northland is Travelers. Great West is Old Republic. National Indemnity, GEICO’s commercial book, Guard, and biBERK are Berkshire Hathaway. State National and National Specialty are Markel, and ACE is Chubb. National Continental and Artisan & Truckers are Progressive, which wrote $10.8 billion of commercial auto premium in 2024, an 11.9% market share, according to AM Best. Those companies aren’t in business to lose money. When a line loses money, they reprice as much as they can.

Commercial auto has lost money for a long time. AM Best reports the line posted an underwriting loss for the 14th consecutive year in 2024, $4.9 billion that year and more than $10 billion over two years, with a combined ratio of 107.2. Commercial auto liability ran at 113, meaning insurers paid out about $1.13 in losses and expenses for every premium dollar. Fourteen of the top 20 commercial auto writers lost money on the line. ATRI’s data shows trucking liability premiums climbed nearly 38% from 2015 to 2024, to a record 10.2 cents a mile. From 2021 to 2024, heavy-duty truck crash rates fell 2.6% industry-wide. Crashes went down, premiums went up and losses kept compounding. Mohave’s Iron Insurance program lost $130 million in a single year, writing carriers that stopped paying premiums while they kept running.

Honest carriers pay first, in premiums priced off a pooled loss experience that includes every unlisted tractor, every rescinded policy and every assigned risk loss in their state. Shippers pay through freight rates. Then it spreads. The companies that write commercial auto also write personal auto, and many of the same cost drivers, from medical inflation to litigation severity, run through both books. The average full-coverage personal auto premium rose 46% from 2022 to 2024, according to Insurify, before dipping in 2025 and climbing again in 2026. Trucking fraud didn’t cause all of that, and nobody should claim it did. It’s one of the losses the whole system is pricing in.

NHTSA’s research on the economic cost of crashes found individual victims pay roughly a quarter of the cost directly. Private insurers funded by every policyholder pay about half, public revenue pays about 9%, and charities, health care providers and other third parties pay the rest. In 2019 public revenue covered about $30 billion in crash costs, roughly $230 in taxes for every household in America. Medicaid covers about 15.8% of hospital costs from motor vehicle crashes and Medicare another 7.3%, before counting victims who become eligible for Medicaid because a catastrophic injury left them unable to work. When a judgment exceeds $750,000, or the RRG behind the policy is insolvent, or the carrier evaporates before the insurer collects its reimbursement, the gap lands on those programs, on hospitals and on the victim’s own insurers.

A fleet declares one truck and pays for one truck. It runs hundreds. The MCS-90 makes the insurer pay when one of them hurts someone, up to $750,000. The insurer’s reimbursement claim against a dissolved LLC goes uncollected. A carrier no underwriter will touch gets written through the state plan, and its losses get split among every auto insurer in the state. Anything above the limit goes to the victim, the taxpayer and the health system. The insurers reprice. The honest fleet down the road pays more, the shipper pays more and the consumer pays more for freight and for their own coverage. The operator who started it registers a new LLC and buys another policy online.

The fatality numbers show what that costs on the road. According to IIHS analysis of federal crash data, 5,174 people died in crashes involving large trucks in 1990 and 4,354 died in 2023. In between, truck miles more than doubled, the carrier population went from about 300,000 to more than 2 million, and the industry adopted ABS, stability control, ELDs and collision mitigation. The passenger vehicle occupant death rate per 100 million truck miles fell 67%. The absolute count barely moved.

12. Brokers and shippers, after Montgomery

For years, brokers argued that federal law preempted negligent selection claims, so a broker that tendered a load to a dangerous carrier couldn’t be sued for choosing it. On May 14, 2026, the Supreme Court unanimously rejected that argument in Montgomery v. Caribe Transport II, holding that negligent hiring claims against brokers fall within the safety exception of the Federal Aviation Administration Authorization Act. Twelve days later, the Court denied certiorari in Total Quality Logistics v. Cox.

A broker’s only federal financial responsibility requirement is a $75,000 surety bond under 49 U.S.C. 13906, raised from $10,000 in 2012, and that bond pays freight charges, not bodily injury judgments. Contingent auto liability coverage is optional. If the carrier has a $750,000 MCS-90 and nothing else, and the damages are $5 million, the plaintiff’s lawyer will look for the next pocket, and more and more often that’s the broker and sometimes the shipper. A broker who collected a certificate and never checked the company behind it, or never asked why a 350-truck carrier with a $791,640 federal penalty was insured through a state plan, bought a document, not a control. The DOT number won’t show a one-truck carrier running 285 VINs. The VIN history will.

13. Know what you’re binding before you bind it

Every fact in this piece came out of federal data anyone can pull: the insurance filing history, the declared fleet against the VINs on inspection reports, the enforcement settlements, the crash file, the out-of-service orders. None of it was hidden. It sits in separate systems that nobody reads together at the moment an agent markets a carrier, a broker tenders a load or an underwriter binds a policy.

I built TruckVerifi for that moment. It searches 2.27 million carrier records from the federal census and puts a carrier’s insurance filing history, lapses, current insurer, renewal timing, inspections, crashes, fraud signals and vetting score on one screen. There’s no digging. An agent can see in a minute whether the carrier in front of them has cycled through eight insurers in five years, sat on assigned risk paper or declared one truck against 285 VINs, then build the submission an underwriter needs to price it. A broker can see the same record before the load goes out. An underwriter can see the exposure they’re about to adopt before the BMC-91X is filed.

When the file needs more, THE TEA goes deeper: the VIN and plate network behind the authority, the officers, phones and addresses it shares with carriers that were shut down, and the lanes the carrier runs most, measured against the crash history of those corridors. A carrier running I-10 through Beaumont construction zones every week isn’t the same risk as one running county roads in Iowa, even with the same truck count on the MCS-150.

14. What would fix it

None of these fixes require Congress to invent anything. Most require agencies and state plans to use authority they already have. Raise the floor. FMCSA has had the authority since 1980. Index the minimum to inflation from the 1980 baseline, about $2.8 million for general freight, and adjust it on a schedule, as Congress already requires for civil penalties. The NAIC Model Act requires insurers to review a carrier’s FMCSA safety data and document the decision before binding a for-hire interstate policy. It doesn’t have to be exhaustive. It has to exist.

• Verify the fleet. FMCSA already logs the VIN on every roadside inspection. Match each carrier’s observed VINs against its declared power units and flag the gap. Tie the MCS-150 power unit count to the BMC-91X filing, require VIN-level verification at binding and quarterly reconciliation after that, and notify FMCSA and the state regulator when the declared and actual fleets don’t match. Several private platforms, including TEA, already run this match. The federal government holds the source data.

• Fix the assigned risk plans for trucks. Price plan coverage on the carrier’s own loss experience, not broad rate-class surcharges. Make a safety improvement plan with measurable benchmarks a condition of plan coverage, cap how long a carrier can stay in the plan without improving, and coordinate across states so a carrier rejected in Illinois can’t restart in Indiana. Adopt California’s inspected-units requirement everywhere. Decide whether a carrier’s risk profile is so poor that no mechanism, voluntary or involuntary, puts it on the highway.

• Disclose who’s behind the paper. Every BMC-91X should identify whether the insurer is admitted, surplus lines, an RRG, a captive or a plan servicing carrier writing assigned risk, and name the parent company.

• Report rescissions. Commercial trucking has no shared database for rescission and fraud actions. An insurer that voids a policy for misrepresentation should have to tell FMCSA, and the next insurer should be able to see it.

• Close the RRG gap for trucking. Require trucking RRGs to meet risk-based capital standards, submit solvency reviews FMCSA can see and meet the same underwriting standard as admitted insurers.

• Tell victims the truth. A claims department that tells a crash victim there’s no coverage because a truck wasn’t scheduled, without mentioning the MCS-90, is telling half the story. State insurance regulators can require disclosure of the federal endorsement in any denial letter on an interstate carrier’s policy.

Congress deregulated trucking in 1980 on the promise that insurance would keep the worst operators off the road. The MCS-90 was the guarantee behind that promise: whatever happens, the public gets paid. Forty-six years later, the floor hasn’t moved; the underwriter has been replaced by a web form; the state plan writes the carriers the web form won’t; and fleets that declare one truck run hundreds. The MCS-90 still does what it says, and the insurer still owes you. Brandon Rogers’ family is still in court.

Links to a few of my older articles on this are here:

1. Jan. 20, 2026:

   Insurance Was Trucking’s Last Real Barrier to Entry. It Collapsed.

2. Feb. 9, 2026:

   How Carriers and Insurers Are Subsidizing Failure

   (this is the Yahoo Finance copy you sent; I didn’t find the FreightWaves URL)

3. Feb. 12, 2026:

   Inside the Shadow Market: 200,000+ Trucking Crashes Without Guaranty Fund Protection

4. Feb. 19, 2026:

   The Dumping Ground: Insuring America’s Most Dangerous Truckers. No Questions Asked.

5. Feb. 22, 2026:

   Insurers Judged by the Trucking “Company” They Keep

6. Feb. 24, 2026:

   A handful of parent companies control America’s trucking insurance market

7. March 24, 2026:

   New data puts a number on the insurance-safety gap in trucking

8. March 25, 2026:

   Raising the trucking insurance minimum is overdue

9. May 26, 2026:

   How legislators and insurers built a trucking crisis

10. May 2026:

    The Iron Insurance Disaster

    (the Mohave and Knight-Swift piece)

11. June 1, 2026:

    Inside hotshot trucking’s ghost fleets

12. talkingwreckless.com

An out-of-service order is the strongest thing a roadside inspector can do without an arrest. It should end the trip. A truck with a defect serious enough to meet the North American Standard Out-of-Service Criteria gets a sticker and cannot move until it is fixed. A driver who is not qualified to be behind the wheel gets parked, and the carrier has to send someone who is. Federal regulation is blunt about the vehicle side. Under 49 CFR 396.9(c)(2), no motor carrier shall require or permit any person to operate, nor shall any person operate, a vehicle declared and marked out of service until the required repairs are complete.

Since June 25, 2025, English language proficiency has been part of that system again. That is the day the Commercial Vehicle Safety Alliance’s emergency amendment took effect, making a violation of 49 CFR 391.11(b)(2) a driver out-of-service condition. The U.S. Department of Transportation has been counting ever since. In its Sept. 30, 2026 enforcement release, FMCSA said more than 31,200 drivers had been placed out of service for English proficiency since the April 2025 executive order.

That number tells you how many orders were written. It does not tell you whether any of them worked.

That question has been open for almost a year. When FreightWaves reported Secretary Sean Duffy’s 9,500 figure in December 2025, OTR Solutions COO Grace Maher asked a fair question: “Where are the pictures of the trucks on the road?” I spent years as a compliance director and fleet executive, and I have reconstructed crashes for litigation since. I know an out-of-service order is only as good as what happens after the officer drives away. So I went and looked at the trucks.

FMCSA’s public daily inspection records from May 13, 2025 through Oct. 29, 2026: 4,253,960 inspection reports, joined to 10.9 million violation records from FMCSA’s Safety Measurement System files. Every report carries the vehicle identification number of the inspected unit, its plate and the USDOT number it was operating under. The driver’s identity is not in the public file. The VIN is. So the analysis follows the truck.

English proficiency measured from June 25, 2025, the day it became an out-of-service violation. The inspection file holds 30,497 English proficiency out-of-service orders on inspections with a usable VIN, spread across 26,893 trucks. In its August 2026 proposed rule, the agency reported 19,045 English proficiency out-of-service orders between June 25, 2025 and March 19, 2026, against just 33 in the first half of 2025.

Of those 30,497 orders, 14,325 trucks showed up at a later inspection. And 2,576 times, the truck’s very next inspection ended in another English proficiency out-of-service order. That is 18% of every truck that came back. Eighty-two trucks drew a second English proficiency order the very next day. Another 319 drew one within a week. A total of 2,955 trucks have two or more English proficiency out-of-service orders, 508 have three or more, and one truck has eight.

An English proficiency order parks the driver, not the truck. A carrier that gets a driver put out of service can legally send a qualified driver to pick up the load, and that truck can be back on the interstate the next morning without breaking a single rule. A truck that draws a second English proficiency order doesn’t prove the same driver was behind the wheel, because the public file doesn’t identify drivers. I also stripped out 85 same-day repeats in the same county, because most of those look like one stop written up twice. None of the numbers in this story count them.

If it was the same driver, an out-of-service order was ignored. If it was a different driver, the carrier put a second driver in that seat who could not pass the same two-step roadside assessment. Either way, the carrier is responsible. Section 391.11 says a motor carrier shall not require or permit a person to drive a commercial motor vehicle unless that person is qualified, and 391.11(b)(2) defines qualified to include reading and speaking English well enough to converse with the general public, understand highway traffic signs and signals, respond to official inquiries and make entries on reports and records. English proficiency is a hiring standard. Roadside is just where the hiring gets graded.

The consequences for ignoring an order are already in place. Under 49 USC 31310, a driver found to have committed a first violation of an out-of-service order is disqualified for at least 180 days and faces a civil penalty of at least $2,500. A second violation means two to five years. An employer that knowingly allows or requires a driver to operate in violation of an out-of-service order faces a civil penalty, and one that does it knowingly and willfully faces criminal exposure. The law is not the gap. Detection is.

When you look at which carriers carry the most English proficiency violations on U.S.-plated trucks, the list is not a scattering of one-truck operators. It is five fleets, and all five list physical addresses in Laredo, Texas.

Forza Transportation Services Inc., USDOT 2490721, MC 862551, reported 1,078 power units and 1,422 drivers on its Feb. 27, 2026 MCS-150. Since mid-May 2025, its U.S.-plated trucks have been cited for English proficiency 245 times, with 212 of those ending in a driver out-of-service order, across 206 different trucks in 28 states plus federal inspections. That is roughly one in five of the power units Forza declared to the federal government. FMCSA’s live system showed Forza with active authority and no out-of-service order as of Oct. 31.

Select Dedicated Solutions LLC, USDOT 1877140, declared 329 power units. Its trucks drew 168 English proficiency citations and 140 out-of-service orders across 126 trucks, or 38% of the declared fleet. Texas International Enterprises Inc., USDOT 2196912, declared 297 power units and drew 164 citations and 122 orders across 117 trucks (39%). FJ Carrier Logistics LLC, USDOT 3162922, declared 230 power units and drew 156 citations and 137 orders across 100 trucks (43%). Tradex Logistics Inc., USDOT 2360323, declared 201 power units and drew 127 citations and 111 orders across 93 trucks (46%).

These five fleets run one or two citations per truck. This is not one bad driver getting caught over and over. It is a hiring pattern showing up across a fleet, in state after state, and it lands on every broker that tendered those loads and every shipper whose freight sat on a shoulder while dispatch found a replacement driver.

FMCSA’s April 16, 2026 enforcement FAQ lays out three violation codes for 391.11(b)(2). Codes 391.11B2Q and 391.11B2S are hard-coded as out-of-service. Code 391.11B2Z covers drivers operating inside the U.S.-Mexico border commercial zones, and it is hard-coded as not out-of-service. In the agency’s words, SafeSpect “does not allow enforcement personnel to alter the out-of-service designation” on any of the three. The August 2026 proposed rule would write that exception into a new 391.11(c)(2): a driver found in violation inside a commercial zone will not be placed out of service unless there is evidence the driver has operated or intends to operate beyond the zone.

The inspection file holds 72,492 border zone English proficiency citations, and only 157 carry an out-of-service flag. The single most-cited truck in the country for English proficiency is a 2022 Ram, VIN 3C7WRAKT1NG396328, operating under USDOT 2787417, registered as J Octavio Rodriguez Tovar and RTH Transportes. It was cited 48 times between June 16, 2025, and Sept. 17, 2026, under four variants of a Mexican plate. It was never taken out of service, and under current policy it could not be. The next four most-cited trucks follow the same pattern, all Mexican-plated, 38 to 46 citations each, zero orders. That is policy working as written. Whether a citation that can be written 48 times on one truck with no consequence is enforcement or record keeping is a question for the docket.

English proficiency is the newest out-of-service condition. It is not the biggest. The same method applied to vehicle out-of-service orders produces numbers an order of magnitude larger.

From May 13, 2025 through Oct. 29, 2026, the inspection file holds 652,660 vehicle out-of-service stops across 517,800 trucks, after collapsing duplicate write-ups of the same truck on the same day in the same county into one stop. In 1,699 cases, the same truck was placed out of service again within a day: 1,452 the next day and 247 the same day in a different county. In 8,580 cases, the next vehicle out-of-service order came within a week. A total of 24,265 trucks have been placed out of service three or more times in that window, and 4,220 have been placed out of service five or more times. The single highest count is 28 vehicle out-of-service stops on one Freightliner, VIN 1FUJGLCK49LAE2141, operating under USDOT 2403092, Bullet Transport Services MX S de RL de CV, on Mexican plate 20EP1K.

A vehicle out-of-service order ends when the repair is made. A truck put out of service for a leaking tire at 9 a.m. can have the tire replaced by noon and be legal the rest of the day. Two out-of-service orders on the same truck a week apart can be two separate failures, both fixed. The inspection file does not record the repair certification, so it cannot tell you which orders were honored.

What it can tell you is when the same truck is parked for the same thing, again and again.

Match every out-of-service violation code on the power unit and the driver to the VIN, then look for the identical code on the same truck at a separate, later stop. A total of 27,095 trucks were placed out of service for the exact same violation at two or more stops. In 9,592 cases, the repeat came within 30 days. In 3,095 cases, the repeat occurred within a week.

The most common repeat was tires leaking or inflated below 50% of maximum pressure (violation code 393.75A3-TAOL), on 4,576 trucks. Second is no record of duty status in the prescribed method, 395.8A1-HOSP, on 4,033 trucks. Third is no valid medical certificate (391.41APC) on 3,740 trucks. Fourth is operating a commercial motor vehicle without a valid CDL (383.23A2-LCDLN) on 2,526 trucks. English proficiency (code 391.11B2Q) ranks fifth at 2,394 trucks, and brakes out of service (396.3A1-BOS) ranks sixth at 1,958 trucks.

A truck that is placed out of service twice for no valid CDL is a truck the carrier kept handing to unlicensed drivers. A truck parked twice with brakes out of service is either a truck that never got fixed or one that keeps failing because the maintenance program isn’t real. Neither of those is a roadside problem. They are carrier problems that roadside keeps catching one stop at a time. Two U.S. trucks show what that looks like up close.

The first is a 2022 Ford F-350, VIN 1FT8W3DT4NEE58321, on Florida plate 18FCHH. A one-ton pickup pulling for hire is a hotshot rig, and this one covered a lot of ground. Between May 23, 2025, and May 20, 2026, it was inspected 16 times in 10 states: Illinois, Idaho, Wisconsin, Mississippi, Louisiana, Tennessee, South Dakota, Montana, Florida, and Pennsylvania, and every one of those 16 inspections ended with at least one out-of-service violation. Twelve included a vehicle out-of-service order.

For its first 10 inspections, through Feb. 23, 2026, the truck ran under Beta Auto Transport LLC, USDOT 4333977, MC 1692478, North Charleston, South Carolina. On Feb. 9, 2026, in Idaho, a single inspection logged 20 violations: nine out-of-service, seven on the vehicle, and two on the driver. On April 9, 2026, in Pennsylvania, the same truck on the same plate was inspected under Gomes E David LLC, USDOT 4022108, MC 1517341, an Orlando carrier that reported one power unit and one driver. That stop logged 22 violations. Twelve days later, on April 21 in Tennessee, it was operating under Knockout Hauling LLC, USDOT 4438695, MC 1747518, Winter Garden, Florida, which reported two power units. Under Knockout, it was put out of service in Wisconsin on April 29 for four driver out-of-service violations and one vehicle, and again in Wisconsin on April 30 for another driver out-of-service violation. It was inspected twice more, in Tennessee on May 12 and Illinois on May 20, with out-of-service violations both times.

As of Oct. 31, FMCSA’s live system showed Gomes E David under a federal out-of-service order dated May 16, 2026, with its for-hire authority revoked. Beta Auto Transport’s for-hire authority was revoked, though its USDOT number remained active. Knockout Hauling’s USDOT number was inactive. One truck, one plate, three carriers, and none are cleared to haul for-hire freight today.

The second truck never left Texas. It is a Freightliner, VIN 1FUJBBCK18LY25779, operating under Tripple J Haulers LLC, USDOT 3755911, of Eagle Pass, Texas. Tripple J’s MCS-150 reports one power unit and one driver, and it was last updated Aug. 29, 2023. FMCSA’s live system shows an active USDOT number and no for-hire operating authority on file. Between May 16, 2025 and Oct. 15, 2026, that one truck was inspected 26 times. Fifteen of those inspections ended with a vehicle out-of-service order. It was placed out of service for brakes on March 4, March 26 and May 15, 2026, and drew further 396.3(a)(1) out-of-service violations on Sept. 4 and Oct. 15.

Across those 26 inspections, the truck displayed 24 different Texas plate numbers. They run 77N120N, 27P120N, 59S188N, 61S188N, 26P222N and on up through 17U943N and 38R010P, and the three-digit block in the middle climbs in step with the calendar, as if each plate came off the same counter. The inspection file does not say what kind of registration those are, and I am not going to guess in print. A plate exists so an officer, a toll authority and a crash investigator can tie a vehicle to its owner. This truck showed 24 different plate numbers in 17 months and kept rolling.

That leads to the last pattern in the data, the one brokers and insurers should care about most. After an English proficiency out-of-service order, the truck’s next inspection showed it operating under a different USDOT number 2,574 times. The fair concession is large here. Trucks are sold. Owner-operators lease on to new carriers. Power-only and lease programs move tractors between authorities every day, and the median gap between the order and the next stop was 102 days. Most of these are ordinary commerce.

85 of those switches came within a week of the order. 307 of them were between carriers that FMCSA’s network data already links through a shared officer, phone number, address, email or plate, built from FMCSA census and registration records. In 102 cases, the old and new carriers share an officer. When the truck stays the same, the people stay the same and only the DOT number changes, that is not a sale. That is the chameleon move, and it resets the safety history every broker and underwriter is relying on.

CVSA first added English proficiency to the out-of-service criteria in 2005. It removed the provision in 2015, and in 2016 FMCSA issued policy memo MC-ECE-2016-006, which inspectors widely read as cite but do not park. For nine years, a driver who could not answer an officer’s questions got a violation and drove on. On April 28, 2025, Executive Order 14286 directed DOT to rescind that memo and restore out-of-service enforcement. FMCSA issued enforcement guidance memo MC-SEE-2025-0001 in May 2025. CVSA’s board used an emergency provision in its bylaws to approve the change without the usual member vote, effective June 25, 2025. FMCSA revised its roadside FAQ on April 16, 2026, and on Aug. 10, 2026, published a notice of proposed rulemaking at 91 FR 51422, docket FMCSA-2026-0826, to codify English proficiency as an out-of-service violation in 49 CFR 391.11.

The agency’s numbers show how fast the shift happened. From Jan. 1 through June 24, 2025, inspectors recorded 7,812 English proficiency violations and 33 out-of-service orders. From June 25, 2025 through March 19, 2026, they recorded 60,399 violations and 19,045 orders. The proposal spends pages on the border zone, the cost to carriers and the cost of replacement drivers. It does not attempt to measure whether parked trucks came back, or how often.

From the carrier’s side. You run a fleet out of a border city. Your driver gets put out of service for English proficiency outside Joplin. The order is a piece of paper in the cab and a record in a database. You send a relief driver, or you do not. If you do not, the only way anyone ever finds out is if another officer happens to inspect that same truck and that same driver before the load is delivered. If you do, the relief driver may be no more qualified than the first, and nothing in the system connects the second failure to the first except the VIN, which nobody is reading as a pattern. If the truck gets parked enough times, you move it to another authority you control, and the history starts over at zero.

The out-of-service order was built to stop the truck. For thousands of trucks, the data shows it stopping the trip.

The fix does not require Congress. FMCSA already collects the VIN on every inspection and scores carriers in the Safety Measurement System from those same records. First, flag any VIN placed out of service for the identical violation at two separate stops within 30 days, and route the carrier to a focused investigation of the program that violation points to, whether that is maintenance, hours of service, driver qualification or hiring. Second, make the out-of-service history follow the VIN. When a truck that was placed out of service appears under a different USDOT number within 30 days, and the two carriers share an officer, address or phone in FMCSA’s own census, treat it as a reincarnation signal, not a new entrant. Third, treat English proficiency out-of-service orders as what 391.11 says they are, a carrier qualification failure. A fleet where 40% of the declared power units have drawn an English proficiency order has a hiring problem that a compliance review can find in an afternoon. Fourth, publish border zone 391.11B2Z citations by carrier, so the public can see whether the exception is being used for short drayage in the zone or as a permanent shelter. All four can be done with authority FMCSA already has.

For brokers and shippers, A carrier’s safety rating and out-of-service percentage are carrier-level averages. The VIN history is truck-level fact, and it is public. For insurers, a fleet with repeat out-of-service orders on the same units is a loss run waiting to happen, and a truck that changes DOT numbers is a truck whose history the application will not show. For plaintiffs’ attorneys, a prior out-of-service order on the same truck for the same defect is notice, and notice is the difference between an accident and negligent entrustment. For the family in the minivan behind that F-350 on an Idaho interstate, none of the averages matter. What matters is whether the truck in front of them should have been parked.

On April 29, 2026, an officer in Wisconsin put that F-350 out of service. On April 30, a Wisconsin officer put it out of service again.

An out-of-service order was supposed to be the last word at the roadside. For thousands of trucks, it is just the first stop of the week.

Carol Larson, 69, paid $120,000 for her cabin and spent 18 months aboard the Odyssey with her sister. Paul and Lynn Montoya, retirees from Wyoming, spent 17 months aboard. Lynn Montoya told Fox News they were tired of being asked for fuel money every two to four weeks. Some sold their homes to buy in.

The headline everywhere is fuel. Fuel is the wrong answer. The same mistake that put those retirees on a dock in Cambodia is sitting inside many trucking companies right now, and most of them can’t see it on their own P&L. Petterson told CBS that Villa Vie was paying about $700 a ton for marine fuel before the war with Iran broke out in late February. Since then, it has paid $2,000 to $3,000 a ton. The ship burns 700 to 800 tons a month. He said the monthly fuel bill went from about $400,000 to about $2 million, and asked where the company was supposed to find the other $1.6 million. Villa Vie’s own statement put fuel at about $1,800 per cabin per month before the war and $6,000 to $8,000 in parts of Asia after it.

The company slowed the itinerary and sat five or six days in each port to burn less fuel, hoping the Middle East would settle down. It didn’t. Nobody I know modeled a quadrupled fuel price into a business plan, and I’m not going to pretend I would have. That leaves out the fact that a business that dies when one input cost goes up fourfold was already living on borrowed time.

The question isn’t why it died in October 2026. The question is how long it ever had.

The model was bad from day 1

When I ran large fleet programs for private equity, the finance people I worked for drilled one idea into me until it stuck: pay more up front for certainty, because month-to-month costs are what kill you. Know which costs are fixed, which are variable, which you control, and which the world controls. Then make sure your revenue moves the same way your costs do.

Villa Vie built the opposite. Here’s how it worked, from the company’s own published pricing and reporting since 2023.

The ship itself is a 1993 hull. It sailed as the Crown Dynasty and later as Fred. Olsen’s Braemar, and Villa Vie bought it for about $13 million and put roughly $12 million into a refit at Harland & Wolff in Belfast. The company told buyers the ship had an expected life of 15 years, through 2039. So on day one you have a 31-year-old asset sold on a promise that it would run until it was 46.

Cabins started at $99,999 and ran into the hundreds of thousands. That bought a cabin guaranteed for at least 15 years. On top of that, owners paid a monthly fee of $1,750, $2,500, or $4,000 per person, depending on the cabin, which covered food, Wi-Fi, housekeeping, and ship operations. Petterson pitched it to retirees as a fixed budget. Live at sea for less than living on land.

A $99,999 cabin spread over 15 years is about $6,667 a year, or $556 a month. That’s the capex the resident paid. The company spent that cash early: on the ship, on the refit, and on a four-month delay in Belfast in 2024, when the ship was supposed to sail in May and didn’t leave until Sept. 30, and the company paid to put residents up while they waited. By the time the Odyssey was underway, much of the one-time money was gone, and what was left to run a 33-year-old ship around the planet was the monthly fee.

Before the war, Villa Vie’s fuel bill was about $1,800 a month per cabin. The cheapest monthly fee was $1,750 per person. On the entry-level cabin, the fee for one person didn’t cover that cabin’s share of fuel at prewar prices, let alone the crew, the food, port charges, insurance, and the maintenance on a ship built when Bill Clinton was in his first year in office.

After the war, it gets worse. If every one of the 203 residents aboard had paid the top fee of $4,000, that would be $812,000 a month. The fuel alone was running about $2 million. At the low fee, the same 203 people bring in $355,250. And the ship was built to carry hundreds more.

That’s the problem in one sentence: fixed-price revenue against a floating cost, with no reserve and no pass-through. The company said putting the fuel increase on residents was not a realistic solution. By then it was already asking them for fuel money every few weeks, borrowing and stretching payroll, according to Petterson. He told CBS the crisis had been going on for nine months.

So no, I don’t think fuel killed the Villa Vie Odyssey. I think it was a failed concept from the day the first cabin sold, and the fuel spike just moved the funeral up. With prewar fuel prices, it might have limped along another year. It was never going to make 2039.

If I’d written a $120,000 check for that cabin, I’d be talking to a lawyer this week. I’d also be realistic about what that gets me. In Chapter 11, secured lenders get paid first, and people holding a contract for a cabin on a ship with no money are likely to be far back in that line.

Trucking is the same business with tires

If you think this is a cruise story, look at your own numbers. The American Transportation Research Institute put the average cost to run a truck in 2025 at $2.336 a mile, the highest in the report’s history. Strip out fuel, and it was still a record $1.854. ATRI found average operating margins for truckload and refrigerated carriers stayed below 1% last year.

Below 1%. Villa Vie had more cushion than that on paper, and it’s sitting in a Cambodian port.

Then fuel moved. The Energy Information Administration put the national average for on-highway diesel at $6.352 a gallon for the week of Oct. 26, up $2.634 from a year ago. It set a record of $6.529 the week of Sept. 21. At today’s price, a truck averaging 6.5 mpg burns about 98 cents of fuel per mile.

Trucking is about as capital-expensive as a business gets. You buy the truck, the trailer, the insurance down payment, and the authority before you haul a single load, and then every mile you run costs fuel, tires, maintenance, and a driver. That’s capex and opex, and the gap between them is your operating ratio. If your operating expenses are 95 cents of every revenue dollar, you’re running a 95 OR and keeping a nickel before interest and taxes. At 100, you’re hauling for free. Above it, you’re paying to haul somebody else’s freight.

The fleets that survive this kind of year aren’t the ones with the lowest costs. They’re the ones that know which costs they can lock down, which ones they have to pass through, and which ones they can buy their way out of up front.

Where paying more up front pays you back

Start with the truck itself, because fuel economy is a capex decision you live with for years. At $6.352 a gallon, a truck that gets 5 mpg spends about $1.27 on fuel every mile. One that gets 6 mpg spends about $1.06. That’s 21 cents a mile. Over 100,000 miles, it’s about 3,333 gallons and $21,173 a year, per truck. Aero packages, low-rolling-resistance tires, the right engine and gearing for the lane, and a governed speed all cost money when you spec the truck or set the policy. They pay it back every month, and faster when fuel spikes. That’s the hedge the Odyssey never bought: it ran a 1993 hull through the most expensive fuel market in years.

Idle is the same math. The Department of Energy says a heavy truck burns about 0.8 gallons an hour at idle and a long-haul truck idles about 1,800 hours a year on rest periods alone, roughly 1,500 gallons. At today’s price, that’s about $9,528 a truck, every year, for heat and air conditioning. An APU, a bunk heater, or a battery HVAC system is a one-time cost against a recurring one. Do that math by truck before you tell me it’s too expensive.

Maintenance is where small fleets bleed the most. ATRI put repair and maintenance at 21.5 cents a mile in 2025, up 8.6%, and found costs were even higher for carriers with five or fewer trucks, largely because they buy older used equipment with little or no warranty. A cheap truck is cheap once. Preventive maintenance on a schedule costs more this month than skipping it. Then the breakdown happens on the shoulder, you pay roadside rates, the load is late, the customer is gone, and the out-of-service order lands on your Vehicle Maintenance BASIC. I’ve sat in depositions where the deferred maintenance record was the most expensive document in the room.

Insurance is the bill that decides whether you have a company next month. ATRI put insurance at 10.6 cents a mile in 2025, up 23.9% from 2021. Most authority revocations trace back to insurance lapsing, usually for nonpayment of premium. Paying in full or putting down more at renewal costs you cash now. Financing the premium costs you interest and starts a cancellation clock every month you’re short. When the cash gets tight, that’s the one payment that can’t slip.

Drivers are a capital decision too, even though they show up as opex. Paying more for an experienced, clean driver, and spending real money on onboarding and training, looks expensive next to the cheapest seat you can fill. Then a claim hits. At Heartland Express, insurance and claims went from 5.4% to 7.3% of revenue in the first quarter of 2026 compared with a year earlier. One bad claim year can move your OR more than a fuel spike, and a negligent hiring claim makes it nuclear.

Cash itself is the cheapest insurance you can buy. Villa Vie didn’t have weeks of operating expense in the bank. It had a ship, a fee schedule, and an investor search. Measure your reserve in weeks of operating expense, not dollars, and build it in good months, because nobody lends to a carrier in a bad one.

The Villa Vie trap in a trucking contract

The cruise company’s dumbest move was selling a fixed price against a floating cost. Carriers do it every bid season.

The Villa Vie fee schedule is a one-year contract rate with no fuel surcharge, or a surcharge capped at a number that made sense last spring. The shipper got a fixed budget. You got the fuel risk. Most surcharge programs key off the weekly DOE/EIA diesel index for a reason: it lets your revenue float with your highest variable cost. Read the table in every contract, check the base price and the step, and know exactly how many cents a mile you lose when diesel jumps a dollar before you sign.

Owner-operators leased on, this one’s for you. Under 49 CFR 376.12, your lease has to spell out your compensation. If you’re on percentage pay and the carrier collects a fuel surcharge from the shipper, read the lease and the settlement to see whether that surcharge reaches you. If it doesn’t, you’re a Villa Vie resident paying for the fuel twice.

Then there’s buying fuel forward. Big fleets hedge with diesel futures, and many carriers holding their margins this year bought fuel months ahead. One NYMEX ultra-low sulfur diesel contract covers 42,000 gallons, which is half a year’s fuel for a five-truck fleet. Smaller carriers get offered the same bet in a different wrapper: a fixed-price program, prepaid gallons, a tank in the yard. Those can work. They can also lock you in at the top. The EIA’s October outlook expected retail diesel to stay above $6 in October and come down gradually, averaging about $4.49 in 2027. If you lock in at today’s price and the forecast is right, you’ve paid up front for the wrong kind of certainty. Know what you burn, what your surcharge already covers, and what the seller is charging over the futures price before you sign anything.

How it lands by fleet size

The one-truck owner-operator with their own authority has the Villa Vie problem in its purest form: the owner pays themselves out of whatever is left, so the business looks profitable when it isn’t. Book your own pay as an expense at a market driver wage before you calculate anything. The two-to-10-truck fleet feels it when the owner stops driving; overhead shows up and every truck has to carry its share. Run OR by truck, because one bad unit can eat the fleet’s margin. The 11-to-50-truck carrier needs a bookkeeper who reads the surcharge tables, not just the invoices. Mid-size carriers need OR by customer, so they can see who they’re subsidizing. The big carriers already hedge. Their risk is buying fleets at the wrong point in the cycle and carrying an underperforming acquisition for years.

Same math at every size. Only the pressure point moves.

Which of your costs are fixed, and which float? Which ones do you control, and which ones does the world control? For every cost that floats and you don’t control, does a line in your revenue float with it? Where can you spend once to stop paying every month? How many weeks could you run if your highest variable cost doubled tomorrow?

If you can’t answer those, you’re not running a trucking company. You’re running a cruise. Somewhere in Sihanoukville this week, a couple from Wyoming is figuring out where to sleep. They did their math on the price of a cabin. Nobody did it on fuel.

The ticket was the cheap part. It always is.

The phone rings at 2:14 a.m. It always rings at 2:14 a.m., or close enough that nobody in safety remembers the difference. A driver sits on the shoulder of an interstate, hands shaking, four-way flashers on, a sedan folded into the corner of his trailer. He doesn’t know yet whether the woman in that sedan is going to live. He doesn’t know whether he got his triangles out in time, whether his dash camera saved the clip or whether the trooper writing on a clipboard 40 feet away is about to hand him a citation. He just knows he needs somebody at the company to tell him what to do. That’s if you have a driver that at least cares enough to do so.

What happens over the next 10 minutes, the next eight hours, the next 32 hours and the next 30 days will possibly go to a jury two or three years from now. Every word the driver says at the scene. Every hour that passes before somebody calls the insurer. Every file that gets pulled, or doesn’t, when the preservation letter lands. The biggest exhibits in any litigation effort won’t come from that night but instead will come from the driver’s application, the MVR nobody signed, or no one has, the camera and/or telematics events nobody coached, the brake defect on a DVIR with no matching work order and the safety policy that says one thing while dispatch emails say another.

This is a discovery guide built from what plaintiff attorneys request, the items I review in countless litigation expert witness cases, and mock audits and consults with some of the biggest and smallest names across the industry, branch by branch. Flip it over and it’s a safety program blueprint, because every branch lists a record that will be used to prove you failed. This piece walks through the whole thing, from the shoulder to the verdict form, then flips it into a program you build before the phone ever rings. The same way the best chameleon carriers develop their business by reverse engineering regs to build their business, plaintiff attorneys, at least the good ones, engineer their strategy based on reverse engineering what you should have done from a compliance perspective as well as an industry standard issue.

Why the post-crash response decides the price

The American Transportation Research Institute studied 600 trucking verdicts from 2006 through 2019 and found jury awards against trucking companies grew 51.7% per year from 2010 to 2018, against general inflation of about 1.7%. Verdicts over $1 million went from 26 in the 2006 to 2010 window to 300 in the 2015 to 2019 window. That trend didn’t level off. Marathon Strategies’ 2026 report on corporate verdicts counted 12 nuclear verdicts in trucking and automotive cases in 2025 totaling $3.4 billion, more than double the $1.4 billion from 15 cases in 2024. Across all industries, verdicts of $10 million or more hit about $25.6 billion in 2025, up 40.7%, with more than 40 thermonuclear verdicts topping $100 million. Generally, the less lag time and the faster you manage the claim or potential claim, the better the outcome.

Not every big verdict survives, and not every big verdict means the carrier was dirty. A Houston jury in 2018 hit Werner Enterprises with roughly $89.7 million in damages after a pickup crossed an icy median on Interstate 20 and struck a Werner truck. On June 27, 2025, the Texas Supreme Court reversed, holding that the Werner driver’s speed and presence created the conditions for the crash but weren’t its proximate cause. Werner won. It took seven years after the verdict. Texas passed House Bill 19 in 2021. On the defendant’s motion, a commercial vehicle trial can split in two: the jury decides liability and compensatory damages first, then hears the employer-specific claims and punitive damages evidence. In that first phase, regulatory violations come in only when they tend to prove causation.

Winning on appeal seven years later is not a business plan. Tort reform in one state is not a business plan. The business plan is making sure that when the plaintiff’s team opens your files, the story in them is the story of a company that saw the risk coming and managed it on paper, in practice and in the culture. Carriers that do that settle cases for what they’re worth. Carriers that don’t get priced on how bad they look. There is a difference between making a victim or plaintiff whole and making a victim rich, and that difference often depends on how you manage your claims and the policies and framework you built your program on.

Minute zero: the scene

The first obligation is the simplest one. Stop. A conviction for leaving the scene costs a CDL holder his license for one year on a first offense under 49 CFR 383.51, on top of whatever the criminal court does. Get the truck as far out of the travel lanes as you safely can, unless moving it would make things worse or law enforcement needs the scene to stay put. Shut it down, set the brakes and check yourself for injuries, because adrenaline will hide a broken wrist for an hour.

Then the warning devices, and this is where I see more cases go sideways than anybody would believe. Under 49 CFR 392.22, the driver has to activate the hazard flashers immediately and keep them on until the warning devices are out. The devices go out as soon as possible and in any event within 10 minutes. On a two-lane road, one goes on the traffic side about 10 feet from the truck toward approaching traffic, and the other two go about 100 feet out, one in each direction. On a divided or one-way highway, they go at 10 feet, 100 feet and 200 feet back toward approaching traffic. If the truck is stopped within 500 feet of a hill, curve or other obstruction, one device goes in that direction somewhere between 100 and 500 feet out so approaching drivers see it before they crest or round the obstruction.

Why does a jury care about triangles? The second crash is often worse than the first. A truck sitting disabled across a lane at night is a target, and when a passenger car runs into it 20 minutes later, the first question plaintiff counsel asks is where the triangles were. The responding trooper’s photos answer that question. So do the dash camera clips. So does the forward-facing camera of the next truck that passed, if plaintiff counsel finds it and subpoenas it. If your driver training records can’t show the driver was ever trained on placement, and your truck inspection records can’t show the truck even carried three bidirectional reflective triangles, you’ve handed them the first chapter of their opening statement.

Next comes people. Check for injuries, call 911 and give a precise location, mile marker and direction of travel. Don’t move an injured person unless they’re in immediate danger, and don’t try to do anything you aren’t trained to do. Stay with them if you can, keep them warm and let them see that somebody cares. Juries remember a driver who knelt by the car. They also remember a driver who stood on the shoulder on his phone.

Then the documentation, and every driver should be drilled on the human factors behind it. When the crash happens, the brain dumps adrenaline and endorphins into the system. Pain drops, strength rises, perception narrows. Everybody at that scene, including the other driver and every witness, is operating on chemistry, and as that chemistry wears off over the next hours and days, injuries reveal themselves and memories shift. People talk to family, talk to friends, talk to a lawyer, and their recollection of who was where and what happened evolves.

The only version of events that doesn’t evolve is the one captured in the first hour. Photos from the fog line toward the point of impact. Photos from the centerline. All four corners of every vehicle at final rest. Close-ups of damage, gouges, debris fields and tire marks. Road conditions, signage, weather and lighting. Names, plates and insurance for every vehicle, names and phone numbers for every witness, the agency and badge number of every officer. Never photograph the injured or the dead, and never wander into traffic to get the shot.

Then what not to do. Don’t argue fault at the scene. Don’t speculate about the cause. Don’t apologize in a way that sounds like a confession, and never, ever tell the other driver the company will pay for something. Be polite, be human, answer the officer’s questions truthfully and stick to facts you saw. Don’t sign anything the other party hands you. The paper can run the other way. Some carriers put what are sometimes called exoneration cards in the cab, a simple form that lets a motorist who admits fault write that down and sign it on the spot. Your driver never signs one. The other driver might.

If there’s fire, the driver needs to know the fire extinguisher requirement in 49 CFR 393.95 and how to use it, pull, aim at the base, squeeze, sweep, from 8 to 10 feet back with the wind behind him. If there’s hazmat, the driver’s training under the hazardous materials rules is what keeps bystanders alive, and the shipping papers need to be where responders can find them. None of this can be taught at 2:14 a.m. It gets taught at orientation, drilled at safety meetings and proven with sign-in sheets, or it doesn’t exist. Make sure it’s not expired.

Hour one to hour 32: the compliance clock starts

The driver’s next call is to the company, and the company’s first job is to determine whether this is a DOT-recordable accident. Under 49 CFR 390.5, an accident means an occurrence involving a commercial motor vehicle on a highway that results in a fatality, an injury to a person who immediately receives medical treatment away from the scene, or disabling damage to one or more vehicles that requires a tow from the scene. A fatality counts if the person dies at the scene or within 30 days. Damage that can be fixed at the scene without special tools, a flat tire, or broken lamps, signals, horn or wipers doesn’t count as disabling. Getting in or out of a parked truck and loading or unloading cargo don’t count as accidents.

That definition triggers two things right away. The first is the post-accident testing decision under 49 CFR 382.303. A fatality requires drug and alcohol testing whether or not anybody gets cited. An injury treated away from the scene, or a disabling-damage tow, requires testing only if the driver gets a citation for a moving traffic violation arising from the accident within eight hours for alcohol or 32 hours for drugs. The alcohol test should happen within two hours. If it doesn’t, the employer has to write down why. At eight hours, the employer stops trying and writes down why. The drug test must happen within 32 hours; at 32 hours, the employer stops trying and writes down why. The driver has to stay readily available for testing, and if he doesn’t, the employer can treat it as a refusal, which carries the same consequences as a positive. The rule doesn’t keep a driver at the scene when he needs to leave for help or medical care. Tests performed by law enforcement under their own authority can satisfy the requirement, but only if the employer obtains the results.

Real carriers fail here. The driver isn’t cited at the scene, dispatch decides no test is needed and the truck rolls. Then the citation is issued six hours later, still inside both windows, after the trooper finishes the report, and nobody at the company circles back. Or the collection site is closed and the 32-hour window lapses with no written reason in the file. Or the test is done, but it’s a non-DOT test under company authority when it should have been DOT, or the reverse. In discovery, the post-accident testing file for that crash will be requested by name. If it’s empty, plaintiff counsel won’t have to prove the driver was impaired. They’ll just ask the jury why the company didn’t want to know.

The second trigger is the accident register under 49 CFR 390.15(b). Every recordable crash goes on it with the date, the city or town and state, the driver’s name, the number of injuries, the number of fatalities and whether hazardous materials other than fuel from the vehicles’ own tanks were released. The register must also include copies of every accident report required by a state or other governmental entity or by your insurer, and it must be kept for three years after each accident. Under 390.15(a), the carrier must also make all records and information about the accident available to an authorized FMCSA or state representative investigating it. Failing to keep an accident register is a critical violation under the safety fitness rating rules, and investigators look for it during post-crash compliance reviews.

While all of that is happening, the records clock is running down. The regulations set minimum retention periods. Under 49 CFR 395.8 (k), carriers must keep records of duty status and supporting documents, including electronic logging device data, for six months. Driver vehicle inspection reports are kept for three months under 396.11. Maintenance records are kept for one year and for six months after the vehicle leaves the carrier’s control under 396.3(c). The driver qualification file is kept for three years after the driver leaves under 391.51. Drug and alcohol records run from one to five years under 382.401 depending on the record. Those are floors. They’re not permission to destroy anything once you know a lawsuit is coming.

The moment a carrier reasonably anticipates litigation, and a fatal crash or a serious injury crash is reasonable anticipation by itself, the duty to preserve kicks in. That means a written litigation hold that suspends every automatic deletion cycle touching that driver, that truck, that trailer, that load and that trip. ELD data and the unassigned driving log. Dash camera footage, both directions, plus the driver’s full event history going back months. Telematics speed, location, hard-braking and following-distance data. Fuel receipts, tolls, bills of lading, dispatch messages, texts and phone records. The DVIRs and work orders for the unit. The engine control module and any event data recorder. Emails between dispatch and the driver. If any of that disappears after the duty to preserve attaches, the court can sanction you and, in the worst cases, tell the jury it may assume what was lost would have hurt you. In federal court, Rule 37(e) reserves that instruction for electronically stored information destroyed intentionally. Plaintiff counsel argues that an overwritten camera clip after a preservation letter shows purpose. State courts set their own rules, and some are tougher.

The tow: your evidence leaves on a wrecker

Most carriers find out what a heavy tow costs the night it happens. I sit on my county’s towing advisory board and work with the sheriff’s office on police-requested towing, so I see this from both the enforcement and carrier sides. On a highway crash, the responding agency usually calls the next company on its rotation list. That’s a nonconsensual tow. Your driver doesn’t pick it up, and your preferred vendor may not be on the list or close enough to matter when the agency needs lanes open. Heavy recovery, rotators, cargo transfer, spill containment and cleanup, traffic control and storage can run a big truck invoice well into five figures, and a spill cleanup can push it higher. The tower can hold the tractor, trailer and often the cargo under a possessory lien until the bill is paid or disputed through whatever process your state allows.

The tow hits you three ways. First, money. If you don’t know what your policy covers for towing, recovery, cargo transfer and environmental cleanup, you’ll find out at the worst time. Physical damage coverage, cargo coverage and pollution coverage are separate questions, and a standard auto policy’s pollution exclusion can leave a spilled-load cleanup sitting on your desk unless you bought the right endorsement. The MCS-90 endorsement guarantees the public gets paid on a final judgment up to the federal minimum, and it lets your insurer come back to you for every dollar the policy itself didn’t cover. It’s no substitute for buying the right pollution coverage.

Second, speed. Storage fees start the day the truck lands in the yard. The faster your claims person gets on the phone with the tower, the agency and your insurer, the less you pay to keep a wrecked unit sitting in gravel.

Third, the truck is evidence. The engine control module and any event data recorder carry speed, brake application, throttle and fault data from the seconds before impact. The brake adjustment, the tires, the lights and the trailer’s air system all tell a story. State troopers will often do a post-crash inspection, and that report becomes an exhibit. If the truck gets repaired, parted out or totaled by the insurer and sold at auction before the plaintiff’s experts get a chance to inspect it, you’ve created a spoliation problem out of a simple property damage decision. The right move is to get the unit to a secure location, hold any repairs, notify the other side and set up a joint inspection and download protocol with both sides’ experts present. Then decide what happens to the iron.

Set all of this up before the crash. Pre-negotiated recovery agreements with heavy towers along your lanes, with rates in writing. A list of who can be at a scene fast for a download. Know what your policy covers and what your deductibles are. And a claims procedure that tells the person answering the 2:14 a.m. call who to call next.

The insurance lag: the 24-hour line on my board

On my Plaintiff Mind Map, there’s a line on the process timeline that reads: claim occurs, collect all data as soon as possible, no more than 24 hours, contact others involved, reduce lag time. Then come the next nodes: plaintiff lawyer retained, suit filed, discovery requested. That line exists because the race starts the minute the crash happens, and most carriers don’t know they’re in it.

Lag time is the gap between the crash and the moment your insurer, or you, if you’re carrying a large self-insured retention, knows about it and starts working on it. Every hour of lag is an hour the injured party spends without hearing from anybody but the billboard attorney who answers on the first ring. Many plaintiff firms can have an investigator, a letter of representation and a preservation demand out before the carrier has even filed the first notice of loss. Once a claimant is represented, the adjuster can’t talk to them directly anymore. A property damage claim that could have been closed with a fast check and a rental car becomes a bodily injury claim with medical treatment that’s built to be presented to a jury. Some of that treatment is real and needed. Some of it is financed by litigation funding and built on lien-based care, where the bill grows because nobody expects the plaintiff to pay it until the case settles.

Report every recordable crash to your insurer the same day, with photos and the driver’s statement. Put your agent, your adjuster and your defense counsel’s numbers on the same card your driver carries. If you have a deductible or a self-insured retention, you are the first adjuster on that claim, and you need somebody who knows how to act like one. If you have excess or umbrella coverage, those carriers usually need notice too, often sooner than people think. Read the notice conditions in your policies before you need them. Late notice is a coverage fight you don’t want.

Inside the company, the crash should go to an accident review committee within days, not months. I recommend the safety director, the claims manager and the manager of the terminal where the crash happened, with the goal of finding root cause and countermeasures, not finding somebody to fire. Was it driver behavior, equipment condition, scheduling, route planning, training or a policy that doesn’t match how the work gets done? Then fix it, write down that you fixed it and prove the fix stuck. I also tell companies that if they’re going to take minutes or record these accident committee meetings, and they have a general counsel, have the GC on the committee as well.

The internal preventability determination that a good safety program depends on can become plaintiff’s Exhibit 1. A memo that says preventable, written before anybody’s seen the reconstruction data, will be read aloud in court. Some carriers handle post-crash root cause analysis at counsel's direction to protect it. Others separate the regulatory preventability review from the coaching conversation. Talk to your defense counsel about how your state treats these documents, and build the process before you need it, not after.

On the regulatory side, use the Crash Preventability Determination Program. Since Dec. 1, 2024, FMCSA reviews 21 crash types through a Request for Data Review in DataQs, including a catch-all type for crashes where video shows the sequence of events. You need the police accident report and supporting documents, photos or video. Reviews currently average about 90 days. A not-preventable finding pulls the crash out of your Crash Indicator BASIC calculation in the Safety Measurement System and gets noted in the Pre-employment Screening Program, though the crash still shows up as listed. That’s one more reason the dash camera clip has to be saved, every time.

The preservation letter and the demand

The preservation letter often arrives before the police report does. It lists every category of record the plaintiff intends to request and puts you on formal notice that destroying any of it will be held against you. If you’ve already issued your own litigation hold, the letter is a checklist. If you haven’t, it’s a countdown.

Then comes the demand. Sometimes it’s a policy that limits demand with a deadline attached, and that’s where carriers and their insurers get into real danger. In Texas, the Stowers doctrine can expose an insurer to the full judgment if it unreasonably refuses a reasonable demand within limits. Georgia has written rules for time-limited demands into statute. Other states have their own versions. A demand like that is sometimes a legitimate effort to settle a case. Sometimes it’s built to be rejected, with a short fuse, conditions that are hard to meet and a missing medical record, so the insurer can later be accused of bad faith and the policy limits can be blown open. Either way, the only safe response is to get it to your insurer and your defense counsel immediately, track the deadline to the minute and make sure the people who decide have the facts in time to make a reasonable call. If you’re carrying a self-insured retention or excess layers, every one of those parties needs to be in the loop.

Staged crashes. Most crash claims are real people with real injuries, but not all of them. In New Orleans, federal prosecutors in Operation Sideswipe have charged 63 people in a scheme to stage crashes with 18-wheelers, with drivers called slammers steering into trucks while passengers claimed injuries, and attorneys accused of running the lawsuits. More than 50 people have pleaded guilty. A carrier with forward and inward video of a staged sideswipe has a defense on day one. A carrier without it has a claim to argue over. A dash camera, an ELD that tells the truth and a driver trained to document the scene are as much an anti-fraud program as a safety program.

Discovery: the Plaintiff Mind Map

Once a suit is filed, discovery turns your company inside out. The written requests, the depositions and the corporate representative deposition under Rule 30(b)(6) or your state’s version of it are built from a predictable list. My board breaks it into branches, and each one maps to a set of requests.

It starts with company management and policy development, and the first question on the board is the one that sinks the most carriers: do they follow the policies they have in place? A written policy you don’t follow is worse than no policy, because it proves you knew the standard and chose not to meet it. Plaintiff counsel will request the employee handbook, the driver and manager DOT handbook, the documented hiring criteria for drivers, managers and mechanics, the substance abuse policy and when it was last updated, the preventive maintenance policy and the hours-of-service disciplinary policy. They’ll ask how the company communicates its rules and expectations and whether employees acknowledged them in writing. They’ll ask whether there’s an emergency action plan and whether anybody has ever drilled it. They’ll ask for the claims handling procedure. They’ll ask, through every dispatcher email and every driver text, whether the culture supports bending or breaking the rules when a load is late. If dispatch or even pay and incentives encourage or facilitate impossible operational demands. Someone paid by the load Mon-Fri when a facility is open 8-4 each day can be read as encouraging drivers to run as fast and as hard as possible to get as many loads completed during that short window.

Then telematics. It’s not the fact that you have a camera that can tell on you, it’s the fact you have telematics that provide data that you managed or didn’t. That’s the difference between making someone whole vs. making someone rich, and it might be the difference between what he said and what you said occurred.

Do you have dash camera footage? Did this driver have a history of events or violations on camera before the crash? What was the corrective action? Do you manage driver behavior events with coaching, training, progressive discipline and, when it comes to it, termination? If your cameras are AI-enabled, how do you manage AI-detected events, and who reviews them? This is where the technology that protects you can bury you. A carrier with 140 distraction events on a driver, an inbox full of unread alerts and no coaching record doesn’t have a camera program. It has a recorded history of knowing and doing nothing.

Then the regulatory profile. Is the MCS-150 current and accurate, or does it show eight power units when the yard holds 40? What do the Safety Measurement System, the SAFER snapshot and the BASIC percentiles show? What’s the operating authority history, including suspensions, revocations and applications? What did prior compliance reviews and civil penalty cases find, and did the company fix it? The gap between what a carrier declared and what it operated is a finding in its own right, and juries understand it immediately.

Then there's driver fitness and the qualification file, where most of my mock audits find the hole. Was the driver medically qualified, and if the medical card was issued for less than 24 months, what condition required monitoring and was anyone watching it? Is the medical certificate on file, and did anybody verify the examiner on the National Registry? After National Registry II changes, is that correct self-certification and CDLIS data on the MVR, and did you check it? Was the CDL valid, properly endorsed and free of restrictions that matter? Were MVRs pulled at hire from every state of licensure for the past three years, and annually since, and who reviewed them and signed off? Could you have done continuous MVR monitoring that would have prevented a disqualified driver from being on the road? Is the application complete, signed and dated under 391.21, and were the previous employer safety performance inquiries under 391.23 done, including drug and alcohol history? Was the driver working a second job, and did anybody track total hours? Did you accept a CDL in lieu of a road test, and would a five-minute road test to determine driver proficiency and fit have prevented the crash? Were red flags at hire documented and managed, or waved through because the company needed seats filled?

Then training. Was the road test given on a compliant form and signed by someone competent to give it under 391.31? What training happened at hire, was it tested and what ongoing training followed? Do you have safety meeting records, with sign-in sheets and topics, showing the company kept teaching after orientation?

Then, hours of service. Was the driver within the rules and within the company’s own policy? What type of duty-status record was required, and was the ELD on FMCSA’s registered list and working? If the carrier claimed a short-haul or other exemption, was the operation inside it on that day? And does the company audit logs against fuel, toll and GPS data, or does it only look when someone gets caught?

Then drug and alcohol and the Clearinghouse. Was the post-accident test done on time and on the right forms, or is the reason it wasn’t done written down? Was the pre-employment drug test completed with a verified negative before the driver ever performed safety-sensitive work? Was the pre-employment full Clearinghouse query run before hire, and is the annual limited query on file with the driver’s consent? Was it the correct test under the correct agency’s rules? Is the person running the program qualified to run it?

Then maintenance. Every DVIR on that unit for at least the past 90 days. Any open defects. Whether every defect has a matching work order showing the repair, signed off by the person who made it and certified before the truck went back out. Whether brake work was done by a qualified brake inspector under 396.25. The full maintenance file, the date of the last annual inspection and the preventive maintenance schedule the company says it follows. A brake defect written up three times and fixed zero times is not a maintenance problem in front of a jury. It’s a choice.

Then load securement and permits. Did the carrier have every license and permit the operation required, and was the load legal and adequately secured? Then hazmat and passenger requirements when they apply. Even I-9 and E-Verify compliance shows up, because a plaintiff’s attorney looking at a carrier’s hiring process will look at all of it.

Then the corporate representative. Somebody from your company will sit in a conference room and be asked whether safety is the company’s number one priority. Whether a trucking company should ever needlessly endanger the public. Whether a company that fails to follow its own safety rules is putting the public at risk. Every one of those questions sounds like a yes. Every yes becomes a rule your company will be accused of breaking. That person needs to be prepared by counsel and have a program behind them that can carry the answers.

The jury: psychology, sociology and the hijack

Everything above is mechanics. What decides the number is how the jurors feel when they go into the deliberation room.

The plaintiff-side playbook is well known and well taught. The reptile approach reframes a crash from what happened on one stretch of road into a question of community safety. Is this company a danger to you and your family? Did it make a rule that endangers all of us? Is this driver still out there? Once the jury stops measuring the crash and starts punishing a threat, the verdict becomes a deterrent rather than a measurement. Anchoring sets the number. A large figure, sometimes the company’s revenue, sometimes a multiple of something, gets said out loud early in trial, and every number afterward is judged against it. Half of an absurd anchor can still feel like a compromise.

The sociology underneath it is just as real. Jurors drive the same roads as your trucks and they’ve been cut off by one. Many distrust corporations by default. Many have read about chameleon carriers, CDL mills and drivers who can’t read a road sign, and they bring that into the box whether your company had anything to do with it or not. Local news coverage and social media shape the jury pool before voir dire. In one case on my desk right now, the exhibit binder includes the sheriff’s office social media post about the crash and the public comments posted below it. The court of public opinion files its brief early.

I tell carriers the same thing every time. You can’t control the playbook. You can control what it has to work with. The reptile approach depends on gaps between what you said and what you did, between your written policy and your operational reality. It depends on a corporate representative who can’t explain the program because one doesn’t exist. It depends on emails where a dispatcher pushes a driver past his hours and nobody in safety pushes back. Close the gaps and the strategy has a lot less to grab. The defense can then do its work: jury selection that finds the people most likely to be swept up in threat-based reasoning, preparation that tells jurors what’s coming, and a safety story told by drivers, mechanics and safety managers who lived it.

Then there’s how you treated the family. Juries punish indifference more than error. A carrier that reached out, paid the property damage fast, showed up and treated the injured family like people, without admitting what it shouldn’t, is a different defendant than one that went silent and lawyered up on day one. Empathy and admission of fault are not the same thing. Your crisis communication plan should know the difference, and it should name one person who speaks for the company.

Building the program: the mind map, flipped

Now flip the map. Every node on that board is a question that will be asked after the crash. A participatory risk program answers each one before the crash, in writing, in practice and in data. I call it compliance-plus: meet the regulation, exceed it where the risk demands, and document all of it in a way that tells a coherent story to the worst-case audience, a jury primed to find what went wrong.

Start by articulating policy, because nothing else holds without it. At minimum, a carrier needs an employee handbook, an FMCSA compliance handbook for drivers and managers, a preventive maintenance policy, an hours-of-service accountability and disciplinary policy, a drug and alcohol policy that includes your Clearinghouse, dilute and marijuana positions, an electronic device policy and a written acknowledgment of telematics and camera recording. Every one of them gets signed at hire, reviewed at least annually and enforced the same way for the top driver and the newest one. If you won’t enforce it, don’t write it.

Build the hiring file like it’s going to be read by a stranger looking for a mistake.

Documented hiring criteria for drivers, mechanics and managers. Applications complete before the first dispatch. Previous employer inquiries and drug and alcohol history pulled and documented, with your good-faith efforts in writing when an employer won’t respond. MVRs from every state, reviewed and signed by a named person against written standards, and continuous MVR monitoring between annual pulls so you know about the speeding ticket in March instead of finding out in a deposition. Medical cards tracked by date, with examiner verification, and monitoring for short-term cards. Road tests by qualified evaluators, on proper forms.

Close the telematics loop. Every camera event gets reviewed, every reviewed event gets an outcome and every outcome gets documented, whether it’s a coaching session, retraining, a written warning or a termination. Track trends by driver, by terminal and by manager. If you can’t staff the review, adjust the alert settings to something your team can review every day, and document why. A camera program you don’t manage is a liability with a lens on it.

Close the maintenance loop the same way. Every DVIR defect gets a work order; every work order gets a signature from a qualified technician and certification before the unit returns to service; and repeat defects get flagged for root cause. Annual inspections on schedule with qualified inspectors. Brake work by qualified brake inspectors. A preventive maintenance schedule the shop follows, with records that prove it.

Run hours of service as a supervision function, not a paperwork function. Audit logs against supporting documents. Watch for unassigned driving. Make sure dispatch and load planning build trips that legal drivers can run, because the email where a planner asks a driver to make it anyway is the most dangerous document in your building.

Build the post-crash response before you need it. A written emergency action plan, drilled at least once a year with sign-in sheets that prove it. An accident kit in every cab with a camera or charged phone, a scene diagram, witness cards, the phone tree, the triangle placement diagram and a plain-language card telling the driver what to say and what not to say. A 24-hour first-call line answered by someone trained to run the checklist: injuries, location, law enforcement, recordable or not, post-accident testing decision with times written down, insurer notified, litigation hold issued, footage saved, tow and download handled. Pre-negotiated heavy recovery vendors along your lanes. A rapid response list with defense counsel and a reconstructionist who can be at a serious scene within hours. A litigation hold template ready to sign. An accident review committee that meets on a schedule, determines root cause, assigns countermeasures and tracks them to closure. CPDP filings when the crash type qualifies.

Manage claims like a business function. Same-day notice to the insurer. Monthly claims reviews with your adjusters. Quarterly loss trend analysis by crash type, driver tenure, terminal and time of day. Reserve reviews you understand. A clear understanding of your deductibles, retentions, excess layers and notice conditions. A procedure for time-limited demands so nobody misses a deadline on a holiday weekend.

Audit yourself before somebody else does. Mock DOT audits, sampled the way an investigator would sample, at least annually. Monthly SMS monitoring with intervention thresholds flagged before they’re crossed. Update an MCS-150 when the fleet changes, not every two years when the system nags you. Document retention mapped to every regulatory schedule, with a hold process that overrides it.

Measure what all of this is worth, because owners respond to math. On a 3% margin, a $10,000 claim takes about $333,000 in revenue to pay for. A $50,000 claim takes about $1.67 million. A $150,000 claim takes about $5 million in revenue. A nuclear verdict takes the company. The safety program isn’t overhead. It’s the cheapest freight you’ll ever haul.

The driver on the shoulder

Go back to that driver at 2:14 a.m. In one version of this story, he’s alone. He doesn’t know where his triangles are. Nobody ever trained him on placement, so he guesses. His camera overwrites the clip by morning because nobody told him how to save it. Dispatch tells him to keep rolling once the trooper lets him go, and the citation comes later, and the test never happens. The tower takes the truck to a yard nobody at the company calls for a week. The insurer finds out on Tuesday. The preservation letter arrives Thursday. Eighteen months later, a corporate representative who started in safety three months before the deposition tries to explain a hiring file with no MVR review and a camera history with 60 unreviewed events.

In the other version, he reaches into a kit, follows a card he’s practiced, places the devices where he was trained to place them, saves the clip and calls a number that’s answered on the second ring by someone who knows exactly what happens next. The test is done inside the window. The insurer knows before sunrise. The truck goes to a secure yard and nobody touches the ECM until both sides can download it. And when discovery comes, the files tell the story of a company that saw this day coming and got ready for it.

Same crash. Same road. Same injured family that should be made whole. Two completely different cases.

The crash takes seconds. The case takes years. What you build before the first decides the second.

Lyndon Dean Meyer was driving in Bee County, Texas, in 2018 when a tractor-trailer headed to Laredo to pick up a load for Adient US jackknifed, crossed into his lane, and hit him. He died on impact. The driver was Satnam Singh Lehal. Lehal worked for OK Trans, which owned the truck. OK Trans got the load from Liberty Lane, through Liberty Lane’s affiliated broker. Liberty Lane got it from Penske Logistics, through Penske’s affiliated broker, Penske Transportation Management. Adient had hired Penske. Four companies stood between the freight and the man behind the wheel, and Meyer’s family sued all of them.

By the time the case reached the Fifth Circuit, the family had dropped everyone except the two Penske companies. A federal judge in Corpus Christi had already ruled for both. Penske Logistics couldn’t be Lehal’s statutory employer, the court said, because Penske’s deal was with Liberty Lane, not with OK Trans or Lehal. The negligent hiring claim against PTM was preempted by federal law. On Aug. 4, 2026, a three-judge panel reversed both rulings in Crane v. Penske Transportation Management, No. 25-40012. Penske never hired Lehal and never owned the truck, and the court held it could still answer for him.

That ruling landed in the same season as two others. On May 14, the Supreme Court decided Montgomery v. Caribe Transport II 9 to 0 and took away the defense brokers had used for a decade to kill negligent selection lawsuits before discovery. On July 23, a Dallas County jury returned a $604 million advisory verdict in Lipe v. Lupus Superior, assigning 23% of the fault to C.H. Robinson and finding that the carrier’s driver was in effect a Robinson employee. Between those three decisions, the industry got a new map of who pays for a truck crash, and the map no longer stops at the company whose name is on the door.

I’ve spent 25 years on most sides of this. I’ve driven, brokered, run fleets under other people’s authority and my own, built safety programs, reconstructed crashes and testified for plaintiffs and defendants. The thing I keep seeing in case files is a carrier that can’t pay. The theory that follows the money up the chain is statutory employment, and it’s older than most of the people now being sued under it.

Statutory employment exists because the trucking industry figured out how to cheat with leased equipment long before anyone had heard of a chameleon carrier. In the 1940s and 1950s, carriers with operating authority hauled freight in trucks they didn’t own, driven by people they didn’t employ, and when something went wrong, they pointed at the owner-operator. The Supreme Court described the problem in Transamerican Freight Lines v. Brada Miller Freight Systems in 1975 as “abuses and evasions of certificated authority and of safety requirements” and “difficulties in the fixing of the lessee’s responsibility.” Congress and the old Interstate Commerce Commission answered with a rule that still governs: if you use the truck under your authority, you own the risk of the truck.

That rule lives today in 49 U.S.C. 14102 and in Part 376 of the federal regulations. Before a carrier performs authorized transportation in equipment it doesn’t own, 49 CFR 376.11 and 376.12 require a written lease that gives the carrier exclusive possession, control, and use of the equipment and complete responsibility for operating it for the term of the lease. The lessee carrier becomes the driver’s employer under the law whether the driver is a W-2 employee, an owner-operator, or a contractor. The definitions in 49 CFR 390.5 say the same thing from the other direction: an independent contractor operating a commercial motor vehicle is an employee for safety purposes, and anyone who leases a CMV or assigns someone to operate it is an employer. The industry calls this statutory employment, and the carrier on the hook is the statutory employer.

Courts never let the paperwork decide it. The Fifth Circuit held in Jackson v. O’Shields in 1996 that the lack of a written lease at the time of a crash doesn’t rule out an oral one. The regulation defines a lease in 49 CFR 376.2(e) as a “contract or arrangement,” and the word “arrangement” has carried weight ever since. In April, a federal judge in Chicago put it more bluntly in Dewey v. K. Split Logistics: “the lease is not the foundation of statutory employer liability,” and “any ‘arrangement’ is sufficient.”

What Crane added is the chain. When one authorized carrier uses equipment owned or leased by another authorized carrier, 49 CFR 376.22 requires a written agreement placing control and responsibility on the carrier doing the using. Penske hired Liberty Lane to move Adient’s freight on Penske’s behalf. Liberty Lane then used OK Trans’ truck and driver. The panel held that the Penske arrangement fell under 376.22, that the rule required Penske to take control and responsibility, and that Penske’s assumption of that responsibility made it Lehal’s statutory employer “regardless of whether Penske and Liberty Lane complied with the formal regulatory requirements.” Nobody had to sign the agreement. The rule assumed it.

The American Trucking Associations and the Truckload Carriers Association filed a joint amicus brief asking the full Fifth Circuit to rehear the case. The Trucking Industry Defense Association filed its own. They argue the panel imposed liability on Penske for a driver employed by a separate authorized carrier that Penske knew nothing about. Meyer’s family answered that Penske had an arrangement with the truck’s operator, carried out through its broker subsidiary and another carrier. As I write this, the court hasn’t ruled on the petition. Until it does, Crane is the law of the circuit that covers Texas, Louisiana, and Mississippi.

None of this would matter much if the carrier at the bottom of the chain could pay. It usually can’t, and the reason is written into federal law.

An interstate for-hire carrier of general freight has to carry $750,000 in public liability coverage under 49 CFR 387.9. That floor hasn’t moved since 1985. A freight broker doesn’t have to carry any liability insurance at all. Its federal obligation is a $75,000 surety bond or trust fund under 49 U.S.C. 13906(b) and 49 CFR 387.307, filed on a BMC-84 or BMC-85, and that money exists to pay carriers and shippers who don’t get paid. Shippers and equipment lessors have no federal floor. They carry whatever their own risk managers buy. The median nuclear verdict, a jury award over $10 million, reached $36 million in 2022.

Put those numbers next to the business model that’s grown up underneath them. A carrier with minimum limits, no equity, trucks titled to a related leasing company, and an office in a virtual suite is the lowest bid on the load board. It wins the spot load because it’s cheap, and it’s cheap because it carries nothing that a judgment can reach. When one of its trucks kills someone, the policy pays $750,000 if the policy was in force, and the company is gone. I’ve watched the same trucks show up under a new DOT number within months. I’ve watched lawyers try for months to serve a carrier whose registered agent, mailing address, and officer all turned out to be dead ends.

The broker captured the spread on that load. The shipper got the low rate. The leasing company collected the payment on the truck. The margin everyone took on the cheap carrier is the exposure they bought, and the plaintiffs’ bar figured that out before most of the freight industry did.

The broker’s version of the climb opened on May 14. Shawn Montgomery was parked on the shoulder of Interstate 70 near Effingham, Illinois, in 2017 when a Caribe Transport II truck hauling plastic pots hit him. He lost his leg. C.H. Robinson had arranged the load, and when Robinson picked Caribe, the carrier held a conditional safety rating built on driver qualification, hours of service, maintenance, and crash-rate problems. For years, federal appeals courts split on whether a negligent selection claim like Montgomery’s was preempted by the Federal Aviation Administration Authorization Act of 1994, which bars state laws related to a broker’s price, route, or service. The Seventh Circuit said it was. The Supreme Court said it wasn’t. Writing for a unanimous court, Justice Amy Coney Barrett held that a claim requiring a broker to use ordinary care in choosing a carrier falls within the statute’s safety exception, 49 U.S.C. 14501(c)(2)(A), because it concerns motor vehicles: the trucks that will haul the freight.

Justice Brett Kavanaugh, joined by Justice Samuel Alito, wrote separately to say brokers who ask hard questions and use reputable carriers should be able to defend these suits, and that proximate cause would still do its work. That concurrence is the broker’s best hope. Lipe is the reason it’s a thin one. The crash in Lipe happened March 25, 2021, on Interstate 20 in Warren County, Mississippi, when a Lupus Superior truck ran into stopped traffic and set off a six-vehicle pileup. Lupus Superior ran about 50 trucks and held a satisfactory rating. The jury split fault 45% to the driver, 32% to the carrier, and 23% to the broker, then found the driver was, in effect, Robinson’s employee. Robinson said it’ll appeal. A satisfactory rating ended the vetting argument. In Dallas, it didn’t.

The other broker theories never went away. In Sperl v. C.H. Robinson, an Illinois appellate court in 2011 affirmed a $23.8 million judgment after finding that Robinson’s control over a carrier’s driver, through fines for late deliveries, loading instructions, and rerouting, made the carrier its agent. That’s vicarious liability by control, and it doesn’t require Part 376. Holding out is another one, when a broker tells the shipper it’s the carrier. Under 49 U.S.C. 14916, anyone who knowingly brokers without authority owes the government up to $10,000 per violation and owes the injured party “all valid claims incurred without regard to amount,” and that liability runs jointly and severally to the company’s officers, directors, and principals. Courts are still arguing over whether a valid claim includes bodily injury. Plaintiffs have started pleading it.

The shipper’s version runs the other way, at least in Texas. A day after Montgomery, the Texas Supreme Court decided In re Home Depot U.S.A., No. 25-0317. A Werner Enterprises driver ran a red light and killed Natalio Garcia, who was on a motorcycle. His family sued Werner and the driver, then added Home Depot, whose freight was on the truck, and said Home Depot should’ve screened Werner and its drivers before handing over the load. Justice John Devine wrote that Texas imposes no duty of care on a passive shipper of ordinary goods that engages a federally regulated carrier operating under its own authority. He called the family’s theory “liability twice removed,” negligent hiring of a carrier that negligently hired a driver.

The opinion is narrower than the headlines about it. The court built its holding on what the family didn’t plead. Home Depot didn’t own, control, or operate the truck, didn’t employ or supervise the driver, didn’t direct how the truck was driven, and didn’t supply a dangerous instrumentality. The cargo wasn’t unusual or improperly loaded. Werner held its own authority and a satisfactory rating, and the court said that mattered: if a carrier’s authority “did not come from Home Depot,” then Home Depot didn’t put Werner’s trucks on the road “in any legally meaningful sense.” The court pointed to its own 2023 decision in United Rentals v. Evans, where a shipper loaded oversized equipment on the wrong trailer without a permit, found the mistake, didn’t tell the carrier, and was held to owe a duty to the people on the road. It expressly reserved the question of cargo that presents an unusual hazard.

Those conditions are the plaintiff’s checklist for every shipper case that follows. Does the shipper hold its own motor carrier authority? Whose carrier name is on the bill of lading? Did the shipper write the carrier standards, remove a carrier from the lane, or demand a particular substitute? Did it set appointment windows that a legal driver couldn’t meet, fine the carrier for being late, or dictate the route? Did it load, secure, or seal the trailer? Is the shipper the consignee, a 3PL, or a carrier affiliate? A shipper that answers no to all of that is Home Depot. A shipper that answers yes to several isn’t passive, and a shipper that holds authority and puts its own name on the bill of lading may not be a shipper at all. That’s the door statutory employment walks through.

Plenty of big shippers hold motor carrier authority. They run private fleets, dedicated lanes, and their own logistics subsidiaries. When one of them accepts freight on its own bill of lading and hands the haul to another carrier, it’s sitting in the same chair Penske sat in. Federal law, 49 CFR 371.2(a), says a motor carrier arranging transportation of freight it has accepted and bound itself to carry isn’t a broker. That’s the carrier’s defense against an unauthorized brokerage claim. It’s also the plaintiff’s proof that the carrier kept carrier responsibility for the load.

Interlining is the old, lawful practice of one carrier passing freight it has accepted to another carrier, usually for a leg of the trip. LTL networks do it every day, and under the Carmack Amendment, 49 U.S.C. 14706, the receiving and delivering carriers stay liable for cargo loss no matter who hauled it. Carmack is a cargo statute, not an injury statute, though it reflects how federal law treats the carrier that accepts the freight.

An authorized carrier can lawfully accept a load and not haul it with its own equipment in only three ways. In a true interline, each carrier physically hauls part of the trip on its own authority. In substituted service under a Part 376 lease or a 376.22 agreement, the accepting carrier uses the other carrier’s truck and takes control and responsibility for it, which is the Crane chair. Arranging for another carrier to perform the whole move is brokerage, which requires broker authority under 49 U.S.C. 13904 and carries the Montgomery duty. Whichever option a company picks, the selection duty applies. A carrier that rebrokers loads without broker authority is in all three chairs at once, and double brokering, when someone takes a load and secretly hands it off to an unknown carrier, adds fraud to the list.

Dispatch services have their own version of this. In June 2023, FMCSA issued final guidance at 88 FR 39368 on what makes someone a broker and what makes someone a bona fide agent of a carrier under 49 CFR 371.2(b). A bona fide agent works for a carrier under a preexisting agreement with no discretion to allocate traffic between that carrier and others. FMCSA said allocating traffic means any discretion over which carrier gets a load, and a dispatcher that picks among its carrier clients isn’t an agent and needs broker authority. In the networks I investigate, the dispatch shop is often the real operator. It books for a dozen authorities that share officers, addresses, phone numbers, and VINs, and the authorities are costumes.

The equipment lessors sit closest to the truck and have had the least attention. The Graves Amendment, 49 U.S.C. 30106, passed in 2005, bars state laws that made a company in the business of renting or leasing vehicles vicariously liable for a renter’s driving just because it owned the vehicle. It applies only when the owner or its affiliate commits no negligence or criminal wrongdoing. It never covered the lessor’s own conduct. Courts keep letting negligent maintenance and negligent entrustment claims proceed against lessors, including a Delaware Superior Court ruling last December in Blades v. Rosson involving New Horizons Leasing and Western Express.

Statutory employment generally favors the lessor. The doctrine attaches to the authorized carrier using the equipment, not the company that owns it. The lessor’s exposure is its own negligence: what it knew about the carrier, what maintenance it took on, and whether it’s a separate company at all. In July I wrote that the reasoning in Montgomery fits a full-service lessor better than it fits a broker. A broker sees a carrier for one load. A lessor signs a multiyear lease, runs a credit underwrite, often maintains the trucks in its own bays, and holds the title. In federal inspection and crash data I analyzed for that piece, trucks that ran under one DOT number showed up in crash records at 8.9%, trucks that ran under two carriers at 19.3%, and trucks that ran under four or five at 26.2%. Among the top 100 pairs of carriers that traded crash-involved trucks, 82 shared an officer. Graves protects an owner “or an affiliate of the owner.” When the leasing company and the carrier are the same people under two names, that affiliate language works against the shield. No court has yet extended Montgomery to a commercial lessor. The pleading is negligent entrustment, and the evidence will be the same public safety data the Supreme Court said a broker should’ve checked.

The list of companies that can end up in the caption keeps getting longer. A carrier’s insurer pays through the MCS-90 endorsement even when the policy itself wouldn’t. Factoring companies are rarely liable, but their UCC filings show who owns and controls a carrier. Freight forwarders take responsibility for the shipments they consolidate. Load boards that start assigning loads instead of listing them start looking like brokers. ELD vendors that manage logs for the same networks that own the carriers end up in subpoenas. Staffing companies that supply drivers raise joint employer questions. Officers get named personally under 14916 and under alter ego and successor theories when the carrier they ran comes back under a new number.

The rule for a shipper, a broker, or a leasing company that wants to stay out of the caption is the one the courts keep writing: what chair were you sitting in, and how much control did you take? A label on a contract doesn’t answer it. The bill of lading, the authority on file, the rate confirmation, the carrier standards, the emails about the pickup window, and the record of who removed which carrier from the lane do. A company that claims to be a passive shipper while writing the carrier’s standards and picking its substitute has documents that say otherwise. A broker that publishes a vetting policy and ignores it on the load that crashed has handed the plaintiff an expert’s standard of care in its own words.

Companies that want to defend these cases need what the plaintiffs want: a written selection standard tied to public data, applied to the carrier on the load in question, at the time of the load, with the result saved. That means authority age, insurance on file, rating status, out-of-service rates, crash history, BASIC alerts, and the relationships between the carrier and every other DOT number that shares its officers, addresses, phones, and VINs. It means the same review at lease origination and renewal for a lessor, and a hard look at any shipper contract that puts the shipper’s name in the carrier box. The broker in Montgomery could’ve pulled Caribe’s conditional rating in about 90 seconds.

The carrier at the bottom of the chain will keep being the cheapest bid as long as the freight market rewards it and the federal floor stays at $750,000. Every company above it that took the savings is now within reach of the same jury, and Crane’s en banc petition is the next thing to watch. If the full Fifth Circuit leaves the panel opinion standing, every carrier that accepts a load and hands it to someone else is the statutory employer of a driver it’ll never meet.

Stack those records together, and you should know who you are dealing with. A credit analyst, an underwriter, a factor’s onboarding team, a lessor’s collateral desk, and a broker’s carrier vetting team all build their files from some combination of them.

The issue is, each of those records is filed by the company being judged, and almost every one can be changed cheaply, quietly, and fast. The networks I investigate know that better than the people extending them credit.

Why I went looking

I spent 25 years on every side of this business: CDL-A driver, owner, freight broker, fleet executive, compliance director, crash reconstructionist. I have filled out both sides of a trucking credit application. I asked for terms as a carrier and extended them as a broker. I ran fleets for a private equity owner, and I have done insurance risk control, finance risk control, and loss control. We advise some of the nation's PE firms, insurers, and finance teams. When I did work for Cortec Group under Groome Management, there's a reason the CFO came to me and not anyone else. Real financial risk comes from real frontline ground-level intelligence. The best minds in finance realize that.

Today I testify in truck crash litigation, and in case after case the same parties end up at the bottom of the pile: the family, the drivers who did not get paid, and whoever lent money against the trucks. Every one of those jobs taught me the same thing. Risk in trucking is almost never just operational. A bad maintenance call becomes a claim. The claim becomes a lawsuit. The lawsuit becomes a default, and the default lands on somebody’s credit desk.

On Monday, I speak to credit and collections professionals at the TRMG Fall Conference in Clearwater Beach, Florida. Preparing for that room forced me to ask a question I had been circling for a year. We talk about chameleon carriers as a safety problem, and they are. What nobody prices is that they are a credit problem first, and credit failures keep unsafe trucks rolling. Many of the risk tools sold to this industry were built by people who have never been close to a truck, based on what somebody told them should be in it. Most vetting confirms a carrier has a DOT number, insurance, authority, and a phone number. We built ours to look behind the name: hazmat spill history, SBA loans, UCC liens, SCAC codes, and the network of people and trucks behind the company. Disclosure: I founded Tea Technologies, which operates TeaTech’s platforms are used for the analysis in this piece, sells carrier risk intelligence, and provides the platform to FMCSA under an evaluation agreement.

The market you are lending into

Start with the numbers that frame every renewal and every credit line in transportation right now.

Commercial auto insurance lost money on an underwriting basis for 14 straight years through 2024, according to AM Best, which put the 2024 loss at $4.9 billion. The 2025 line improved and still ran underwater, at a 114.7 combined ratio and roughly $1.9 billion in losses. The American Transportation Research Institute’s 2026 cost update puts insurance at 10.6 cents per truck mile, up 23.9% since 2021. That cost hits your customers’ margins before it ever hits your aging report.

Verdicts are the reason. ATRI found the average trucking verdict above $1 million rose from $2.3 million in 2010 to $22.3 million in 2018, a 967% increase. Marathon Strategies’ 2026 edition of its corporate verdicts report found trucking and automotive nuclear verdicts of $10 million or more totaled $3.4 billion in 2025, up from $1.4 billion in 2024, on fewer cases. Across all industries, the firm counted about 200 nuclear verdicts totaling $25.6 billion, up 40.7%.

Then the floor moved under brokers and shippers. On May 14, 2026, the Supreme Court ruled 9-0 in Montgomery v. Caribe Transport II, No. 24-1238, that federal law does not preempt state negligent-selection claims against freight brokers. A jury can now review the carrier-selection decision. In July, a Dallas County jury returned a $604 million advisory verdict against C.H. Robinson as broker of record in Lipe v. Lupus Superior, a fatal crash case; the company has said it will appeal.

The insurance market answered immediately. A SONAR analysis published Sept. 9 reported primary broker liability renewals up roughly 40% to 60%, excess layers up 50% to triple digits, two underwriters out of the broker auto liability market since May, and a remaining pool of about 10 carriers, citing TD Cowen. Scopelitis partner Greg Feary told Transport Topics that one broker client’s premiums tripled a week after the ruling. Cottingham and Butler’s Chris Vogel described a broker whose renewal cut its limit from $10 million to $5 million, doubled the deductible, and turned the limit into an aggregate.

Follow that chain to its end, and you arrive at a credit desk. Exposure turns into defense costs and settlements. Those need capital. The capital needs insurance that just got more expensive and thinner. The broker or carrier that cannot fund all of that comes to a lender, a factor, or a supplier for terms. The supply chain has never carried more financial risk than it does right now, and the parties carrying it are underwriting from the thinnest files in the industry.

The weak end of the market is already breaking. FreightWaves counted more than 20 trucking-related Chapter 7 and Chapter 11 filings in a single 30-day window this spring, including the liquidation of Standard Forwarding Freight, a 92-year-old carrier with 14 terminals. Trucking payroll employment hit its lowest level since September 2020, according to Bureau of Labor Statistics data FTR analyzed.

None of that means trucking credit is collapsing. The Equipment Leasing and Finance Association’s CapEx Finance Index for July 2026 reported delinquencies at 1.8% and an average loss rate of 0.46%, the lowest in nine months, on record monthly new business volume of $14.3 billion. Most carriers pay their bills. Most fleets that run several DOT numbers do it for ordinary reasons: a separate entity for equipment, one for real estate, a brokerage kept apart from the fleet. Ryder and Republic run multiple numbers in the open, and in our data their entities share every identifier, from officers to trucks, because they have nothing to hide. Most liens are lawful. Most lenders sue small businesses every day, and a closed docket often means the bill got paid.

The losses do not spread evenly. They pool where the paper and the operation have been deliberately separated.

What the rules actually say

Credit teams should know five federal rules by number, because each one is a clock or a ceiling that decides who gets paid.

The first is the safety rating clock. Under 49 CFR 385.13, a property carrier that receives a notice of a proposed Unsatisfactory rating is prohibited from operating beginning on the 61st day after that notice; hazmat and passenger carriers stop on day 46. When the rating becomes final, FMCSA issues an out-of-service order, and it may revoke the carrier’s authority. An out-of-service order means no legal revenue. Most credit agreements do not treat it as a default.

The second is the insurance clock. Under the federal MCS-90 endorsement, either the insurer or the carrier can cancel by giving 35 days’ written notice to the other and 30 days’ notice to FMCSA. When coverage ends, FMCSA moves to revoke authority. The same endorsement says something most creditors have never read: when the insurer pays a claim it would not otherwise have owed under the policy, “the insured agrees to reimburse the company.” A rescinded policy does not just leave your customer uninsured. It can also create a new creditor.

The third is the ceiling. The federal minimum liability for general freight, in 49 CFR 387.9, is $750,000. It was set in 1980 and has not moved. A serious crash outruns it before the first deposition, and the plaintiff’s lawyer goes looking up the chain for whoever has more.

The fourth is the broker bond. Under 49 CFR 387.307, a broker carries a $75,000 surety bond or trust. It exists to pay carriers. It does not pay a crash claim or your invoice. Since Jan. 16, 2026, FMCSA can suspend a broker whose bond falls below that floor and isn't replenished within seven business days.

The fifth is the one this piece is about. Under 49 CFR 386.73, adopted in 2012, FMCSA may order a carrier or broker out of service if it operated under a new identity or as an affiliated entity to avoid an order, a penalty, or association with a poor compliance record, and the agency may merge the new company’s record with its previous incarnation. The factors the rule lists- common officers, addresses, phone numbers, equipment, drivers, and customers- are the same factors a creditor needs to prove successor or alter ego liability. The government wrote your collection checklist 14 years ago.

Case one: the paper died, the trucks kept working

On March 14, 2025, Auxilior Capital Partners Inc., a Plymouth Meeting, Pennsylvania, equipment finance company, filed a verified complaint in the Northern District of Illinois (Case No. 1:25-cv-02702) against RTL Leasing LLC, RTLX Ltd., and Reserve Truck Lines Ltd. Co. and Jacob Kuenzl. The complaint is the best credit case study I have seen in this industry because the lender laid out its own mistakes in sequence.

Auxilior had financed equipment for a Joliet carrier called Merging Express LLC. According to the complaint, Merging Express told Auxilior it had subleased the equipment to RTL Leasing, then ceased operations and liquidated. Auxilior foreclosed. As the sublessee, RTL Leasing had possession of the trucks. Instead of sending recovery agents into a yard, Auxilior “agreed to finance RTL Leasing’s purchase of the equipment previously owned by Merging Express.”

On July 26, 2024, Auxilior and RTL signed Loan and Security Agreement No. XXX2906 for $2,113,122.29, payable in 48 monthly installments of $48,607.71. The collateral was 29 units: 11 Freightliner and Volvo sleeper tractors from model years 2018 to 2020, and 18 dry van and reefer trailers from 2017 to 2022. The loan exhibit carries a 4.90% rate. The Wall Street Journal prime rate that day was 8.50%. RTL Leasing, an Illinois LLC formed in January 2021 at 13717 U.S. Route 30 in Plainfield, has never held a USDOT number or operating authority. It could not legally haul a load, which means it had no freight revenue of its own to pay the note.

Reserve Truck Lines, an Iowa company at 222 3rd Ave. SE in Cedar Rapids, USDOT 3175112, signed a corporate guaranty. Kuenzl signed a personal guaranty. RTLX also signed a corporate guaranty, and three days after closing, on July 29, 2024, a first amendment made RTLX a co-borrower and terminated that guaranty. Paragraph 16 of the complaint concedes that RTL never got new titles issued, so every certificate still named Merging Express, a company that had already liquidated, as the owner.

On Dec. 30, 2024, the last business day of the year, the parties signed a second amendment “as an accommodation to RTL Leasing.” It accepted $0.00 payments for September 15 through December 15, 2024, months that had already passed, then one payment of $12,883.44, five of $8,772.77, six of $15,000, 12 of $30,000, 36 of $45,000, and a final balloon of $400,632.70. On paper, a loan four payments behind became current with one signature. The amortization schedule attached to the complaint shows interest capitalizing during the zero-dollar months, pushing the balance from $2,113,122.29 to $2,148,433.28, with the first scheduled dollar of principal reduction on payment 11.

RTL and RTLX missed the first payment due under the new schedule on Jan. 15, 2025, and every payment after it. Auxilio’s complaint claims $2,173,343 plus 18% contract interest. In paragraph 53, it puts the fair market value of all 29 units at $1.1 million. The lender asked a federal judge for a writ of replevin authorizing the U.S. Marshal “to use all necessary force, including the force necessary to break locks,” and stated that it “has been unable to secure the Equipment by peaceful means.”

The complaint said the equipment was believed to be at 13717 S. Route 30, Suite 111, in Plainfield, “or wherever it may be found.” Federal roadside inspection records show where some of it was found. Collateral VINs were inspected under a carrier that appears nowhere in the loan agreement, the guaranties, the UCC filing, or the lawsuit, starting in late 2024. Eleven days after the suit was filed, one of the 2022 Utility reefers was at roadside. Over the following months, units surfaced under carriers in California, Ohio, Florida, Texas, and Tennessee. On July 11, 2025, the Illinois Secretary of State involuntarily dissolved RTL Leasing for failing to file an annual report. FMCSA’s live record today shows Reserve Truck Lines with an active USDOT number and its for-hire authority revoked. The outcome of Auxilior’s case is not public.

The lender refinanced a failed borrower’s sublessee instead of taking the loss. It lent to an entity that could not legally earn money with the collateral, while the company that did earn money with it signed nothing. It accepted a title defect at closing. It watched one guaranty disappear three days in. It restructured into a larger balance on depreciating iron. It did not watch the VINs, which were sitting in free federal inspection data before the restructure was signed. None of those decisions were illegal. Each one made the next one worse.

Case two: the veneer and the ledger

The second case is the one I would hand to any lender who has ever been dazzled across a desk.

Dragos Sprinceana founded DMG Consulting & Development Inc., which did business as Goldcoast Logistics Group, USDOT 2190975, in the Chicago suburbs. Its last MCS-150 before the trouble, filed Sept. 29, 2022, reported 350 power units and 334 drivers at 2130 Point Blvd. in Elgin, Illinois. I am a retained expert in litigation involving DMG. Everything below comes from federal and state records, court dockets, and his own public statements.

Start with what a lender would see. In his own social media posts, Sprinceana described celebrating the 2024 election result at Mar-a-Lago, meeting future National Security Adviser Michael Waltz there in January 2025 to discuss Romania, hosting an April 2025 gala at the club that he told the Romanian newspaper Gândul drew about 700 guests, and, in a Nov. 20, 2025, post, dining at Mar-a-Lago with then-Homeland Security Secretary Kristi Noem and Secret Service Director Sean Curran. Federal Election Commission records show campaign contributions from him and his wife to the Republican National Committee, members of Congress, and a leadership PAC. In 2024, he sued a celebrity jeweler in Miami-Dade County over two watches he said the jeweler took to sell for him and never paid for. Wealth, access, and a 350-truck fleet. That is the veneer.

Now the ledger. FMCSA’s enforcement records show case IL-2021-0097-US1688, closed May 17, 2022, with a $791,640 settlement for violations of 49 CFR 383.37(a), knowingly allowing drivers to operate without a valid CDL, and 49 CFR 395.3, the driving-time limit. A compliance review dated May 30, 2023, produced an Unsatisfactory rating. FMCSA placed DMG out of service on Aug. 27, 2023, and issued a second out-of-service order on Sept. 12, 2023, for failure to pay. A second enforcement case, IL-2023-0120-US1713, closed Oct. 19, 2023, for $97,990. That is $889,630 in settlements, and the public record does not show it was collected. The Elgin terminal was sold in a sale-leaseback weeks after the first order. Successor numbers in the same orbit, Goldcoast Carriers Inc., USDOT 3014047, and Freight Transportation Group Inc., USDOT 3008326, went out of service on Aug. 15, 2025, and April 20, 2026.

On Jan. 25, 2023, Illinois UCC file 029264910 recorded a financing statement listing Dragos Sprinceana as the debtor at a Boca Raton address and Dragos Sprinceana as the secured party at a commercial registered agent suite in Glendale, California. He filed a lien against himself. A perfected lien puts a claim on assets ahead of later judgment creditors. For a credit audience, that filing alone should end the conversation.

The creditors came anyway. On Oct. 16, 2025, U.S. District Judge Robert W. Gettleman entered default judgment in Ealom v. Goldcoast Carriers Inc., DMG Consulting & Development Inc. and Dragos Sprinceana, case 1:24-cv-05217, finding the defendants liable under the Fair Labor Standards Act and the Illinois Wage Payment and Collection Act. The court noted that no defendant, “nor anyone purporting to represent Defendants,” appeared at the hearing. Five drivers received $56,574.52 in judgments, the largest $22,377.60 to Anthony Ealom, and their lawyers were awarded $48,129.09 in fees and costs. Those men hauled the freight. They are judgment creditors now.

On Feb. 26, 2026, Chief Judge Virginia M. Kendall entered default judgment for Equify Financial LLC against Goldcoast Financial LLC, DMG and Sprinceana, jointly and severally, case 1:25-cv-07533, for $2,478,219.84. The order awarded Equify immediate possession of 14 CIMC Cool Globe 53-foot reefer trailers with Thermo King Precedent S-600 units, listed by VIN, and contained a sentence I have never seen in an equipment order before: “DRAGOS SPRINCEANA shall assist EQUIFY FINANCIAL, LLC in locating and recovering the Outstanding Equipment.” A federal judge had to order the debtor to help the lender find its own collateral.

Finding him is its own line item. In one creditor’s case, Bank Capital Service documented 13 failed attempts to serve DMG and 11 failed attempts to serve Sprinceana personally. In an equipment lease case in New Mexico, Inland Lease and Rental v. DMG, 1:24-cv-00608, the court filings describe registered addresses that turned out to be virtual offices and executive suites before the court approved alternative service. Federal dockets list 13 cases with DMG or a Goldcoast entity as a party, from equipment lessors to a utility to Centennial Bank’s admiralty action against a vessel. Both judgments above were entered by default. He has not been charged with a crime.

Follow the financing, and you see why this is a credit story and not just a safety story. Illinois and Arizona UCC indexes show trust vehicles registered at 9300 Metcalf Ave. in Overland Park, Kansas, the headquarters of Shamrock Trading Corp., parent of RTS Financial, filing against Sprinceana and a long list of Goldcoast entities starting in 2017. In February 2024, six months after the first out-of-service order, a Chicago-area factor took assignment of a lien position across the network, and in February 2025 Goldcoast Carriers filed a new financing statement with the same factor. A financing statement is not a default, and a factor doing its job is lawful. It does show capital still attached to the trucks 18 months after the government told them to stop rolling.

People tell you who they are. In trucking, they also file it. The veneer is what a borrower wants you to see. The ledger is what the courts and the government recorded. Believe the ledger.

Wall Street already learned this lesson in 2025

If the trucking cases feel small, look at what the same pattern did at scale. First Brands Group, an Ohio auto parts maker reporting about $5 billion in annual sales, filed for bankruptcy on Sept. 28, 2025, with $12 million in cash and more than $9 billion in liabilities. On Jan. 29, 2026, federal prosecutors in Manhattan unsealed an indictment charging its founder and his brother with wire and bank fraud, alleging fake, inflated, and double-pledged invoices submitted to factoring partners and inventory pledged to multiple lenders. “In some instances, invoices were generated for transactions that had never occurred,” the U.S. Attorney’s Office said. The defendants are presumed innocent. In the Tricolor Auto Group collapse that same fall, a Chapter 7 trustee alleged collateral was double pledged and loans were sold more than once.

Private credit spent the next year relearning one rule: verify the collateral independently, because the borrower’s own reporting is the thing being falsified. Trucking runs on factoring. Its collateral moves at 65 miles an hour and changes plates when it crosses state lines. If the most sophisticated lenders in the country can be fooled by documents produced by the borrower, a credit analyst approving a 30-day line for a two-year-old carrier from an MCS-150 and a certificate of insurance has no margin at all.

Size is not safety, and fraud is not the only way to lose

It would be convenient if this were only about bad actors. It is not. Some of the biggest losses trucking credit has taken came from large, long-lived companies that simply could not make money in a volatile market.

Yellow Corp., the less-than-truckload carrier that operated for nearly 100 years, shut down in late July 2023 and filed for Chapter 11 protection in Delaware in early August with about 30,000 employees. It carried about $1.5 billion in debt as of March 2023, including $729.2 million owed to the federal government, most of it from a $700 million pandemic-era Treasury loan made in 2020. As of that March, Yellow had repaid $230 million of the loan’s principal. The lender of last resort was the U.S. taxpayer, and the taxpayer was in line with everyone else.

Celadon Group, an Indianapolis truckload carrier with about 3,300 tractors and 10,000 trailers, filed on Dec. 9, 2019, and shut down, eliminating about 4,000 jobs, many of them drivers stranded on the road. Its collapse followed an accounting scandal built around buying and selling trucks at inflated values through its Quality Cos. affiliate to make its finances look stronger than they were. Celadon agreed to pay $42.2 million in a 2019 resolution with the Justice Department, and Quality's former president pleaded guilty. Federal charges against two former Celadon executives were dismissed with prejudice in 2022. The mechanism a credit analyst should remember is the one that matters at any size: related-party equipment sales at prices nobody independently verified.

Those two cases bracket the problem. A carrier with real assets, real freight and a century of history can still default when rates fall, and costs climb. A carrier inflating its equipment values with an affiliate can look healthier than it is right up to the day it closes. And a chameleon can look exactly like either one on paper. The credit cycle hits honest operators too, and the bad actors hide inside that noise. That is why underwriting has to be built on what the operation actually does, not how big it is or how long it's been around.

Outside capital cuts both ways too. I ran fleets under a private equity owner across 28 states and more than 50 terminals, and the discipline was real: systems, audits, compliance programs, and diligence designed to protect an investment the owners intended to grow and sell. A private equity sponsor has every reason to want the operation underneath the paper to be exactly what the paper says. Venture money plays a different game. Convoy, the Seattle digital freight broker backed by Jeff Bezos, Bill Gates, Alphabet’s CapitalG, and T. Rowe Price, raised more than $1 billion, reached a $3.8 billion valuation in 2022, and shut down on Oct. 19, 2023. Its founder blamed “a massive freight recession and a contraction in the capital markets.” Carriers that had hauled its loads were left sorting out who would pay them. Growth funded ahead of profit can vanish as fast as a chameleon, and the carriers, shippers and lenders on the other side of the ledger find out at the same moment the employees do.

The same goes for the insurers behind your customers. Risk retention groups are owned by the members they insure, which means their capital is only as strong as the fleets inside them. When Nevada placed Spirit Commercial Auto RRG into permanent receivership on Feb. 27, 2019, it carried $199 million in unpaid losses; a forensic audit by FTI Consulting found at least $30 million missing, and its surplus was restated from $13.4 million to $703,000. The same operator had run Federal Motor Carriers RRG, which went insolvent in 2011. An insurer can fail as quietly as a carrier, and when it does, every customer it covered becomes uninsured for every open claim at once.

Judge the customer by the insurer it keeps

There is a question almost nobody on a credit desk asks: who insures this customer, and who else do they insure?

Insurance history is the earliest underwriting signal you can borrow for free, because somebody upstream already read the file. In February, I published an analysis of 2.84 million insurer-to-carrier relationships across 1,310 insurers in FMCSA’s licensing and insurance data. Thirteen insurers with 500 or more carriers each held 0.65% of the relationships and accounted for 6% of all crashes and 6% of fatal crashes. The top 10 insurers wrote more than half of all new carriers’ first policies.

One 310-truck carrier in that work, KG Line Group, moved from Artisan and Truckers Casualty to Sutton National to AmTrust, then to Universal Casualty Risk Retention Group on Jan. 21, 2026. Oklahoma’s insurance commissioner flagged Universal Casualty for hazardous financial condition in 2024. When a customer walks down the insurer ladder like that, the market has already told you something.

Risk retention groups deserve their own line in every credit file. Under federal law, they cannot participate in state guaranty funds, and their policies must say so. Seventy-six RRGs in our analysis insure about 29,423 motor carriers linked to 209,854 crashes. When one fails, your customer's claim has no insurance behind it. Vermont’s regulator said Global Hawk Risk Retention Group was “so deeply insolvent that the vehicles are effectively uninsured” when it was liquidated in 2020 with about $23.8 million in liabilities against $3.4 million in assets, covering roughly 1,008 trucks. James Richardson, seriously injured in Chicago, could not collect on a $1 million settlement after Spirit went into receivership.

How the policy was bound matters as much as who wrote it. Instant-issue programs let a carrier attest to its own drivers and trucks and buy coverage with a credit card in minutes, with nobody reading the file until there is a claim. Underwritten programs put a human on the record before binding and again at renewal. On a certificate of insurance, the two look identical. When the instant-issue insurer finally reads the file after a crash, it reaches for misrepresentation clauses. A rescission leaves the carrier uninsured for its own losses, and under the MCS-90 it can leave the carrier owing the insurer for whatever it paid the public. That is one more creditor at the table, chasing the same empty account you are.

Brokers can be the shell too

Credit teams tend to treat brokers as the safer counterparty: no trucks, no drivers, a bond on file. After Montgomery, that assumption is expensive.

Look at a broker’s FMCSA licensing and insurance history the way you would look at a borrower’s payment history. One broker in active litigation, which I am not naming for that reason, shows FMCSA opening involuntary revocation proceedings against its authority five times between 2014 and 2024, each discontinued when the required filing came back. Sixty-seven days after a fatal crash on one of its loads, its trust fund filing ended, and a surety bond replaced it; a year later, a new surety replaced the first. Its federal registration today lists no company officer and no telephone number. Changing sureties can be ordinary. Five revocation proceedings and an empty registration are not.

The Gold Coast network ran a broker too. Cargo 247 Inc., USDOT 4304928, registered as a broker with zero trucks and zero drivers at a residential apartment in Pompano Beach, Florida. It filed its MCS-150 on the same day as a carrier in the same orbit, and its Merchants Bonding Co. bond was canceled April 10, 2026. Trans Recovery Solutions posted a public collection notice for unpaid freight charges owed by DMG’s brokerage, and Baxter Bailey & Associates lists it in its debtor database. The carriers who hauled those loads and never got paid are creditors too. They just do not have a docket.

Now add the affiliation layer. The networks I investigate do not stop at the carrier and the broker. They wrap the factor, the lessor, the dispatch floor, the insurance agency, and sometimes the ELD vendor around one family. An ELD that the Gold Coast owner publicly described as his own was formed in Wyoming in July 2024, 10 months after his carrier was put out of service, at a commercial registered agent address, with his name nowhere on the filing; it appears on FMCSA’s registered ELD list. A Chicago-area lender describes itself as selling trucks, renting them, factoring the freight, providing insurance, and selling fuel- everything a new carrier needs from one address. In the Super Ego network, Floyd Inc.’s chief executive testified in April 2025 that he runs both Floyd and Super Ego Holding and that Super Ego holds no operating authority; six carriers, including Stevens Trucking, Western Flyer and Freymiller, filed a federal RICO complaint in the Eastern District of Texas on Sept. 23, 2026, alleging more than 70 carrier entities and 1,500 equipment transfers. Those allegations have not been answered or decided.

Here is the credit point. When the hours-of-service logs, the insurance placement, and the receivables all come from inside the family, every document you rely on was produced by the borrower. That is the First Brands lesson in a truck cab.

How we got here

Congress set the $750,000 minimum in the Motor Carrier Act of 1980 and never indexed it. The Interstate Commerce Commission, which once policed who could hold authority, was abolished at the end of 1995, and registration moved to a volume-based system. In 2012, the Government Accountability Office reported in GAO-12-364 that new applicants with chameleon attributes had a severe crash rate of 18%, three times the 6% rate of other new entrants. FMCSA adopted the reincarnation rule the same year. For more than a decade, a carrier could register online with very little verification; when FMCSA replaced that system with Motus in May 2026, the Department of Transportation said that under the old process “all they needed was an email, name, and physical address,” and that several thousand registration numbers were tied to fraudulent carriers. Every carrier in your customer file before this spring came through that door.

Meanwhile, capital got easier. Factoring made cash available on day one. Instant-issue insurance made coverage available in minutes. Used equipment flowed out of the 2021 boom into the hands of anyone with a down payment. Authority itself became a product; in July I documented an online marketplace that listed 108 operating authorities as sold for a combined asking price of about $1.54 million. By 2025, you could assemble a trucking company out of other people’s capital in a week.

How the shell is built on your money

Walk through it the way the operators do. You form a leasing LLC that never applies for a DOT number. It borrows against the trucks, so the lender sees a leasing company and a title. You run the trucks under a separate carrier with its own DOT number, insurance, and factor, so the broker and insurer see a carrier. You put a relative, a working driver, or a registered agent service on the paperwork, so the process server finds nobody. You buy insurance that binds without questions, and when an underwriter finally declines you, you move one rung down the ladder. You sell your receivables the day they are created, so your trade creditors are unsecured behind a factor that filed first. If you are careful, you file a lien against yourself before the lawsuits arrive.

When the safety rating comes, you have 61 days. You stop paying the equipment note, because nothing is owed that you can be made to pay quickly. The carrier number goes out of service. The trucks move to a new number with a new name on the door, often the same day, and the plates follow the paperwork to a new state. The debt, the fines, the judgments, and the crash history stay with the dead number. The equipment, the drivers, the customers, and the people in control walk across. In this model, a dissolved entity is not a failed business. It is an exit.

That is why the same indicators that predict nonpayment predict crashes. A carrier that will not keep its own drivers’ wages current will not keep its brakes current. Credit extended to that operation does not just risk a write-off. It keeps the trucks on the road.

Who is holding it

Run the ledger across one of these networks and every party absorbs something except the equipment. The lender holds a judgment against an entity with no assets and collateral it cannot locate. The factor holds receivables that were sold twice, or that belong to a company that no longer exists. The insurer pays the public under an endorsement it cannot cancel retroactively and chases reimbursement from a shell. After Montgomery, the broker holds negligent-selection exposure for picking the carrier. The shipper holds the same exposure one step up, and its own insurer is reading the ruling too. The lessor holds a lease with a company whose name came off the door months ago. In an asset-backed securities structure, the loss does not stop at the originator; it runs to the noteholders. Taxpayers hold uncollected federal penalties. Drivers hold wage judgments. Somewhere, a family holds a policy-limits tender for $750,000.

Everybody underwrote a different slice of the same company from a different file. Nobody saw the whole thing. That is not a flaw in the arrangement. That is what the arrangement is for.

What would close it

The system built to make trucking companies identifiable has become the system bad actors use to make themselves unidentifiable to the people who pay for them. Most of the fix sits with the parties extending capital, and most of it costs nothing.

Underwrite the operation, not the entity. Pull roadside inspections for every VIN on an equipment schedule, and compare the trucks a customer declares on its MCS-150 to the trucks inspectors actually see. Ask who holds title, who holds authority, and who earns the revenue, and if the answers are three different companies, find out why before you fund. Get titles reissued before closing, not after.

Run UCC searches on the company and every officer, and read the filings to see who is already first, for self-liens, and for trust vehicles that tell you who is factoring the freight. Pull federal and state dockets on the company, its officers, and any prior company those officers ran. Read the insurance history in FMCSA’s licensing and insurance system: how many insurers in three years, whether any were risk retention groups, and whether any cancellation notices are pending. Check whether a predecessor ever carried an Unsatisfactory rating or an out-of-service order.

Write the federal clocks into your paper. A notice of a proposed Unsatisfactory rating, an out-of-service order, and an insurance cancellation notice should be events of default because each is public, each starts a countdown, and each ends the customer’s legal revenue. Monitor identity the way you monitor payment behavior: officer changes, address changes, new DOT numbers sharing officers or VINs, and a fleet that jumps with no financing trail. And when a customer flips anyway, use 49 CFR 386.73 as your evidence map for successor and alter ego claims, follow the VINs to the new number, and find the factor and the lessor, because they know where the receivables went.

Regulators have their own short list, and none of it requires new legislation. FMCSA can require every MCS-150 to identify every person who owns or controls a carrier or broker and every DOT number each has controlled in the past decade, under penalty of perjury, and check that list against its own out-of-service, Unsatisfactory, and unpaid-penalty records before granting or keeping authority. It can refuse to keep active a registration that names no officer. It can use the reincarnation rule it already has. States can reject a registered agent filing that names a person their own vital records list as dead.

The judgment creditor

Anthony Ealom drove for Goldcoast. On Oct. 16, 2025, a federal judge in Chicago awarded him $22,377.60 in unpaid and underpaid wages and liquidated damages, after the company and its owner stopped showing up to court. He is now a judgment creditor of a 350-truck fleet, standing in the same line as an equipment lender holding $2.48 million, a factor, a utility, and the United States government.

The DOT number was supposed to tell you who you were lending to. For a chameleon, it only tells you who they used to be.

Since May, the question I get more than any other from brokers and shippers is some version of this: which carrier selection tool should we be using now? They want me to name a vendor, a score, or a cutoff that will keep them out of court. I get why. I’d want that too. I don’t have it to give, and neither does anyone else.

On May 14, the Supreme Court decided Montgomery v. Caribe Transport II, and it was unanimous. Justice Barrett wrote that a state-law negligent-selection claim against a broker falls within the FAAAA’s safety exception because choosing a carrier determines which trucks and drivers hit the road. In plain terms, brokers lost the preemption shield many of them had been leaning on, and negligent-selection claims can proceed under ordinary state negligence law.

What the Court didn’t do matters just as much. It didn’t write a carrier selection standard. It didn’t say which data a broker has to check, which vendor to use, or which number disqualifies a carrier. Justice Kavanaugh’s concurrence made the point that brokers who use reasonable selection procedures and contract with reputable carriers should be well positioned to defend these claims. Reasonable is the word that does the work there, and the Court left it to the rest of us to define.

“There’s no standard” is true, and it won’t save you

I’ve worked both sides of the aisle in these cases. On the plaintiff side, the argument is that the broker should have known. On the defense side, the argument is often that no standard existed to hold the broker to. Both arguments are real, and I’ve made versions of both. Here’s what I’ve learned sitting in depositions: the second one is a lot easier to make when the company can show you its own written standard.

There’s no federal selection standard for carriers. There’s also no federal standard for most of the decisions you make in life, and you still make them. We rely on values, ethics, morals and common sense. For some people, faith draws the line. For others, the law does, and the prospect of jail is a pretty effective line all on its own. None of those come with a vendor score attached. Businesses are no different. You don’t get to skip setting a line just because nobody in Washington drew one for you.

So don’t wait on me to set it. Don’t wait on Highway, or Carrier411, or GenLogs, or FreightValidate, or any consultant or expert witness on either side of a courtroom. We can help you build it. We can’t be your standard. Your standard has to be yours, in writing, in your policy, and enforced the same way on a Tuesday in February as it is the week after a catastrophic crash.

Compliant isn’t the same as defensible

This is the conversation I have with motor carriers all the time, and it applies to brokers and shippers the same way. The regulations are the floor. A compliant program checks the boxes the regulations require. A defensible program is one where you can explain, under oath, why you made every decision you made, and why you didn’t make the ones you didn’t.

Take driver qualification. Under 49 CFR 391.23 and 391.25, a carrier has to pull a driver’s motor vehicle record before hiring and review it at least once a year. That’s compliant. Plenty of carriers now use continuous MVR monitoring services that flag a suspension, a DUI or a new violation the week it hits the record, not 11 months later. Under 391.33, a carrier can accept a valid CDL in lieu of a road test. That’s compliant too. Some carriers still put every new driver in the seat with a trainer before dispatching them, CDL or not.

None of those choices is required, and none of them is wrong. What matters is that you chose on purpose and wrote down why. If your policy is an annual MVR and a CDL in lieu of a road test, own that. Say why it fits your operation, your freight and your risk. Just know that when a driver with a suspension you could have caught in March kills someone in July, the first question in the deposition is going to be why you only looked once a year. “The regulation only required once a year” is an answer. It’s rarely a good one in front of a jury.

Carrier selection works exactly the same way. Whatever tool you pick, whatever data you check and whatever cutoff you set, build the policy as if you’ll have to defend it to 12 people who’ve never been inside a brokerage. Because one day you might.

Know what your data actually measures

Half the metrics these systems use as vetting criteria aren’t performance indicators. They’re enforcement prioritization tools.

The Safety Measurement System is the clearest example. FMCSA describes SMS as the tool it uses to prioritize its own workload, deciding which carriers its limited investigators look at first. It was never built to certify a carrier as safe or unsafe for a broker. Congress went further in Section 5223 of the 2015 FAST Act and ordered FMCSA to pull BASIC percentiles and alerts for property carriers off the public website, which it did on Dec. 4, 2015. They’ve been off public view ever since. Many of the vendor scores on the market rebuild or estimate those hidden numbers, and different vendors don’t always get the same answer for the same carrier.

The coverage gaps are just as big. When SMS launched in 2010, only 92,184 of the 758,682 active carriers in FMCSA’s database were ranked in even one BASIC, about 12%. Of those ranked carriers, 52,967 had at least one alert, more than half. Alerts are common among carriers big enough to be measured, which shows there isn’t a clean line between safe and unsafe. Safety ratings are thinner still. Of 690,091 interstate freight carriers eligible for a rating in 2021, about 94% didn’t have one, according to FMCSA’s own annual data. FMCSA has said itself that because it can only rate a small percentage of carriers each year, a rating doesn’t necessarily reflect a carrier’s current safety posture.

None of that means the data is useless. A published Conditional or Unsatisfactory rating is a federal finding, and it was central to the facts in Montgomery. Out-of-service rates, crash history, authority status, insurance filings, and inspection detail are all real signals. The mistake is treating an enforcement queue as a safety verdict. If your policy rejects every carrier with an estimated alert, you’ll exclude a big share of the authorized, insured, measured carriers in the country, many with out-of-service rates below the national average. If your policy approves every unrated carrier with no alert, you’ve waved through most of the market without looking at anything. Both are indefensible for the same reason: you can’t explain what the number actually told you.

What a defensible program looks like

I’m not going to hand you a scorecard, because a scorecard copied from someone else is exactly what you can’t defend. Here’s what I look for when I review a program, whether I’m hired by the company or by the people suing it:

• It’s written down, and the people using it can find it.

• It says what you check, where the data comes from and how often you check it again after onboarding.

• It explains why each criterion is in there and what risk it addresses.

• It sets clear hard stops, like an Unsatisfactory rating, no active authority or lapsed insurance, and separates them from items that trigger a closer look.

• It states who can approve an exception and requires the reason in writing.

• It’s applied the same way every time, and you can prove it with records.

• It gets reviewed and updated on a schedule, and you keep the old versions with their dates.

• The people applying it were trained on it, and you can show that too.

That last point about dated versions matters. Standards change. FMCSA has been working on SMS methodology changes for years, and vendors change their models all the time. A standard that changes every few months isn’t much of a standard, so don’t let a vendor’s latest model change be your policy. Let your policy say how you’ll evaluate new data when it shows up. Then when someone asks what you were doing in 2023, you can hand them the 2023 version, not today’s.

The same goes for the data itself. When FMCSA’s own systems disagree, and right now MOTUS, SAFER, and the MCMIS downloads don’t always match, some people stand there like they’re on a broken escalator, waiting for somebody to come fix it. The steps still work. You walk them. Your policy should already say which source you check for what, what you do when they conflict, and how you document it. FMCSA’s registration office has reportedly told the industry that SAFER is the current source of truth for out-of-service status and that MOTUS will eventually be the authority. That’s useful to know, but your program shouldn’t need a statement from Washington to function. Pick the source, write down why, check the conflict, note it in the file and keep moving.

The deposition test

Every decision in your program should pass one test. Picture yourself in a conference room with a court reporter, a plaintiff’s attorney and the worst crash your company has ever been connected to. The attorney asks, “Why did you do it this way?” If the answer is already written in your policy, with a reason that makes sense to someone outside trucking, you’re in good shape. If the answer is “that’s what everybody does” or “there’s no rule that says we had to,” you’re not.

Ask for help building it. That’s what risk professionals, attorneys and people like me are for. But don’t wait for someone to hand you a standard, and don’t plan on arguing there wasn’t one.

Make the decision, write it down, enforce it and be ready to defend it, the same way you would anything else that matters.

I was on the couch with my son last night, watching Robin Hood (the Russell Crowe version), and I told him King John was his 23rd-great-grandfather. He lit up. Genealogy, DNA, and finding and reuniting lost relatives were my gateway drug to data and research. My only real hobby. Then he started talking about Richard, how young the Lionheart was when he died, and then I thought about that. The odds of being here.

I’m two years older right now than my dad was when a motorcycle crash killed him. I’m six years older than my older sister was when years of drug abuse finally took her. I’m 17 years older than my younger brother was when he overdosed. Both of my grandfathers died last year. One of them got a cancer diagnosis, dropped a hundred pounds, and was gone six months later.

I sat there doing that math, and it hit me how much we take for granted. I wake up every day assuming I’ve got decades left, that I’ll make it to 80 or 90 or 100. History tells a different story. Tomorrow might be it. Today might be it. Every person I’ve ever stood over at a crash scene woke up that morning assuming the same thing I do. I have time, only to find out that they jumped to the front of the line and today's their day, oftentimes with someone else's help.

Then the aspergian autistic guy took over and crunched the math. King John died in 1216. Twenty-five generations separate him from my son, and on paper that’s 33,554,432 ancestor slots in that one generation alone. Every one of those lines had to hold. The Black Death swept Europe from 1347 to 1352 and killed roughly 30% of the people in the places it hit, close to half in the worst cities. For most of human history, about half of all children died before they grew up. Then came the famines, the trenches of World War I, the 1918 flu, and World War II. Every ancestor my son has, and every ancestor you have, made it through all of it long enough to have a child. Not one link broke, or none of us would be here.

Our 6th-great-grandfather Robert Shield, George Washington’s second cousin, died on the last day of the Battle of Yorktown in 1781. The last day.

Now think about the odds stacked up behind every single person on the road this morning. Centuries of plague, war, and early death couldn’t stop them from being born. And then they die on an ordinary weekday because a carrier skipped a drug test, a broker never checked who it handed the load to, a driver ran seven hours past his limit, or a motorist was looking at a phone. That is insane to me. All of that survival, every one of those odds beaten, ended by somebody who couldn’t be bothered to do the job right.

I’ve done this work for 25 years: driver, broker, fleet executive, compliance director, crash reconstructionist, expert witness. I can’t unsee any of it. People crushed in the seat, mashed between the steering wheel, the seat, and the floor. Bodies missing a head, missing arms. A split abdomen. The smell of iron and everything else that comes out of a human body when it fails all at once. The weight of the air at a scene. The cries, the screams, the families arriving and finding out on the shoulder of an interstate.

I don’t describe that for shock. I describe it because the people who cause it rarely have to see it, and the people who pay for it almost never connect what they pay to what happened.

Here is one from last week.

A young woman was driving home from college. She was on the phone with her father. They were talking about her boyfriend and the future they had planned: marriage and a long life together. Then a tractor-trailer hit her, and her father heard it happen. He called and called 911, asking for updates from hundreds of miles away.

When I went through what was left at that scene, her whole life was on the ground. A romance novel in the floorboard. Her phone in a case covered with pictures of her and the boy she was going to marry. Her suitcase had burst, and her clothes were everywhere. Everything that made her somebody’s daughter, scattered across the pavement.

The truck driver got back in his truck a few hours later and went on about his day.

Then the record came out. He had driven 18 hours the day before. Federal rules cap driving at 11 hours inside a 14-hour window under 49 CFR 395.3. There was no driver qualification file, the folder 49 CFR 391.51 requires every carrier to keep on every driver it puts behind the wheel. There was no post-accident drug or alcohol test, even though 49 CFR 382.303 requires one after any crash that kills somebody: alcohol within eight hours and drugs within 32. His motor vehicle record was pulled six months after he was hired, when 49 CFR 391.23 gives a carrier 30 days. No training was on file, and Part 380 has required entry-level driver training for new CDL holders since 2022.

Behind that one truck sat a web of related companies. Every one of them now says it wasn’t the employer. None of them controlled the driver. The truck wasn’t on the policy. The family that buried their daughter is now fighting a maze of LLCs built, as far as I can tell from the record, for exactly this moment.

That is what a bad actor looks like after the crash. They have no trouble with the bodies they leave or the families they break. They have trouble with the bill, and they’ve built their whole operation so somebody else pays it.

A really good example here is Dragos Spinceana and Gold Coast adding a driver who died five years earlier to their company as President and Agent; after he died, they did this to try and avoid accountability. If they add a dead guy, 1) who's going to complain their identity is stolen, and 2) who cares, right, he’s dead? They didn't even file a workers' comp claim. Rocky Chhean's daughter buried him using GoFundMe proceeds from grassroots donors. Meanwhile, we watch him celebrating America with an active $1 million fine from Mar-a-Lago.

So let’s talk about who pays it.

Start with the bodies. According to NHTSA’s Fatality Analysis Reporting System, 5,472 people died in crashes involving large trucks in 2023. About 70% of them, 3,837 people, were not in the truck. They were in cars, on motorcycles, or on foot. NHTSA’s early estimate puts total traffic deaths in 2024 at 39,345. That’s more than a hundred people a day, every day, on roads we all assume are safe because we share them with drivers we assume are qualified.

Most people never see the next number. FMCSA’s own Crash Cost Methodology, updated in 2025, puts the average cost of a fatal large truck crash at $15,230,414 in 2023 dollars. An injury crash averages $326,810. A crash where nobody gets hurt still runs $49,398. Those figures count medical bills, emergency response, lost wages and lost productivity, property damage, legal and court costs, and the value of the life itself.

NHTSA did the national math in its last full report on crash costs. In 2019, motor vehicle crashes cost the country $340 billion in economic losses, about 1.6% of the entire U.S. economy. Count the loss of life and quality of life, and the total climbs to nearly $1.4 trillion. That came to roughly $1,035 for every person living in the United States.

NHTSA found that people who were not involved in the crashes paid about three-quarters of those costs through insurance premiums, taxes, and the time they lost sitting in the backup. Taxpayers alone covered about $30 billion, roughly $230 for every household in the country.

The carrier that skipped the DQ file, skipped the MVR, skipped the drug test, and ran its driver seven hours past the legal limit did not save money. It moved the cost onto everybody else. The ambulance, the trooper, the medical examiner, the hazmat crew, the hours of a closed interstate, the trauma bed, the court system that now has to sort out which of a dozen LLCs actually owned the truck. You paid for that, whether you’ve ever heard of the carrier or not.

Then there’s the cost that never shows up in a crash cost table.

On June 20, 2024, Dalilah Coleman was 5 years old and riding in her family’s car on Highway 395 in San Bernardino County, California, when traffic slowed for a construction zone. The tractor-trailer behind them didn’t stop. Six vehicles were involved. Dalilah’s brain swelled so badly she was put on life support. She spent three weeks in a coma, had part of her skull removed to relieve the pressure, and spent six months in the hospital. She’s 7 now. She’s nonverbal; she’s learning to walk again, and her family is saving for another surgery next year. Her father, Marcus Coleman, drives a truck for a living. The driver charged in that crash, Partap Singh, is in immigration custody.

Dalilah lived. When everybody survives, the headline goes away, and the family is left with a different child than the one they put in the car that morning. No settlement figure gives her parents back the voice they used to hear.

The trauma doesn’t stop at the people who were physically hurt. A 2025 meta-analysis in Health Promotion Perspectives pooled 82 studies of road crash survivors and found a post-traumatic stress disorder rate of 20.3%. One in five. That is the brother in the back seat who won’t ride in a car anymore. The mother who can’t drive past the exit. The father who heard his daughter die over the phone and will hear it every night for the rest of his life.

I know a little about what that does to a family, because my family is made of people who were taken early. I’m the oldest and last left at only 45. You don’t get over it. You build your life around the hole.

Now follow the money through the rest of the system, because the worst actors don’t just cost the families they hit. They cost every good carrier in this country.

When a carrier with no qualification file and a driver running 18 hours puts somebody in the ground, the verdict that follows doesn’t stay in that courtroom. It lands in the actuarial tables every insurer uses to price commercial auto. The Council of Insurance Agents and Brokers found commercial auto premiums up 10.4% in the first quarter of 2025 and another 8.8% in the second quarter, outpacing nearly every other line of business it tracks. Brokers and insurers pointed at the legal system, and some of that is fair. But juries are not handing down huge numbers because they hate trucks. They do it when a plaintiff’s attorney puts a file in front of them that looks like the one I just described.

The good carrier, the one that actually pulls the MVR in 30 days and actually tests its drivers after a crash, pays those higher premiums too. The shipper pays them in its freight rates. The vendor pays them. And then you pay them at the register, because everything you own, eat, or wear moved on a truck at some point. The bad actor saved a few hundred dollars by skipping compliance, and the whole supply chain carries the difference.

Meanwhile, the bad actor often doesn’t pay at all. That’s what the maze of related companies is for. Federal minimum liability coverage for general freight is $750,000. FMCSA puts the average fatal truck crash at more than $15 million. When a carrier insured at the minimum kills somebody, the gap between those two numbers doesn’t vanish. It falls on the victim’s family, their health insurance, Medicaid, Social Security disability, and the taxpayers behind all of them. Then the same owners open a new company under a new name with the same trucks, and do it again.

Then comes the part nobody outside a courtroom sees: what the bad actor does to the family after the funeral.

The first move is almost always the same. The carrier, or its lawyer, goes to the widow, the estate, or the parents and says, more or less: we’re nobody. We’re a little trucking company. We don’t have anything. But we’ve got this policy over here, $750,000, maybe a million, and you can have that. That’s all there is. And a lot of families take it. They’re grieving, they’re broke, they want it over, and a check with six or seven figures on it looks like the end of the road.

If you are that family, do not take that offer. Not like that, and not ever without a lawyer who knows trucking looking first. That “nobody trucking company” very often has a dozen sister companies behind it, a broker who handed it the load, a shipper who picked it, an owner who leased it the truck, excess and umbrella coverage nobody mentioned, and assets that magically moved to a cousin’s LLC last spring. Remember the numbers above. FMCSA puts the average fatal truck crash at more than $15 million. A $750,000 policy is the floor the federal government requires, not the value of your husband’s life. If you’re facing this and don’t know who to call, email me at robcarpenter@theteaintel.com. I will find you a lawyer who actually knows trucking, and I will help you against a bad actor carrier. IF YOU EVER NEED GUIDANCE on a lawyer or a case or an offer, message me. I do not charge for this stuff. I will find you a real professional.

I don’t say that as someone who grew up on the plaintiff side. For most of my litigation career, I defended trucking companies. I still do. That was my side of the courtroom for years, and I believed in it, because the carriers I defended were mostly run by people who came up the way I did. When they hurt somebody, they felt it. Shame meant something. Responsibility meant something. Making the family whole was the first question, not the last one. Often, our goal was to mitigate a good carrier's issues to make victims whole again, without making the world rich off the trucks.

Over the past 20 years, I watched that change. Too many of the carriers and drivers I see in files today are not the same people who ran this industry 30 and 40 years ago. The question isn’t how we make this right anymore. It’s how close to legal we can run, and when it goes wrong, how little we can pay. And if the cheapest way to pay less is to destroy the people we hurt, so be it.

I had a case this fall where a father and husband was killed. By every account, he was a good man, and the crash was no fault of his. The truck belonged to a foreign carrier, driven by a temporary foreign driver who never should have been qualified to drive it. In discovery, that carrier’s side went after everything that man’s family had left: his life, his record, his dignity, his widow’s, all the way down to what their sex life was like before the crash. I know why lawyers ask some of those questions. When a spouse claims the loss of a marriage, the marriage is part of the case. But there is a line between proving damages and humiliating a widow into taking less, and that firm walked right over it.

That case is a big part of why I now take plaintiff cases too. Very selectively. We don’t work with ambulance chasers, and we don’t take cases that shouldn’t be brought. Our goal is making survivors and victims whole, not necessarily rich. We will take plenty of cases against bad-actor carriers and bad-actor drivers, the ones who did everything they could to skirt the rules and get into a truck and onto a highway they had no business being on.

I am a proponent of the trucking industry. I’ve spent my whole adult life in it, from driver to broker to owner to executive to risk and expert guy. I get it all. More than that, I’m a proponent of a quality trucking industry, and if we want to keep whatever quality we have left, we have to defend it from the people dragging it down. Every carrier on the road carries a moral, ethical, and professional obligation to the mothers, fathers, sons, daughters, sisters, and brothers it shares that road with. Somewhere along the way, too many forgot what that obligation means. We lost the concept of shame. We lost personal responsibility, and the simple decency of making whole the people we harm. We’ve let the worst drivers and the worst carriers pollute the driver pool, the carrier pool, and the highways the rest of us have to drive on.

So what does a crash actually cost? Put it all in one place.

It costs a life, or a child who comes home different. It costs a family the rest of its future together. It costs the first responders who carry those scenes for the rest of their careers. It costs the court system years of work untangling who was responsible. It costs every honest carrier higher premiums, every shipper higher rates, every consumer at the checkout, and every taxpayer public money spent cleaning up a mess somebody else made to save a buck.

The common thread in most of the crashes isn’t some freak event nobody could see coming. It’s a decision. A decision to put an unqualified driver in a truck. To skip the background check. To run past the hours limit. To ignore a medical problem. To let a mechanical defect ride. To ignore what the driver was on. To hide behind paperwork when it goes wrong. Distraction, licensing failures, medical emergencies, failed equipment, drunk and drugged driving: every one of those starts as a choice someone made long before the crash.

That is why Dalilah’s Law matters. H.R. 5688, sponsored by Rep. David Rouzer of North Carolina, would crack down on non-domiciled CDLs, require commercial drivers to be proficient in English, shut down CDL mills and ban foreign dispatch services, among other provisions. The House Transportation and Infrastructure Committee advanced it 35-26 on March 18, 2026.

That was 206 days ago. The full House still hasn’t voted. Politico reported in September that the bill doesn’t have the votes to pass the House right now, with lawmakers from Florida and New York objecting. The House is out until after the Nov. 3 midterms and has roughly 20 scheduled days in session left this year. The Senate version, S. 3917, filed by Sen. Jim Banks of Indiana the day after the State of the Union, has sat in the Commerce Committee since Feb. 25 without a hearing. If nothing passes by noon on Jan. 3, 2027, when this Congress ends, every version dies, and the fight starts over with a new bill number. Government funding and highway programs both run out Dec. 11, and my read is that the only way this gets to the president this year is riding one of those must-pass bills, the same way the English out-of-service requirement became law inside a spending bill in February.

You can argue over individual provisions, and people will. What you can’t argue with is the premise: the license and the authority are supposed to mean something, and right now, too often, they don’t.

What no law will do. It won’t bring back the girl coming home from college. It won’t give Dalilah her voice back. It won’t undo a single scene I’ve walked. The only thing any rule can do is make the next one less likely, and make the people who cut every corner pay their own bill instead of handing it to the rest of us.

When the movie ended, my son went to bed still talking about kings and crusades. I sat there a while longer. Nobody on the road tomorrow expects it to be their last day either. The least this industry owes them is a driver who is qualified, rested, sober, and accounted for, hauling for a company with its name on the line.

We all think we have time. Too many of the people I’ve stood over found out they didn’t.

At about 5:35 p.m. on Saturday, April 15, 2023, a tractor-trailer eastbound on Interstate 10 near mile marker 843, by Smith Road and the Goodyear plant in Jefferson County, Texas, failed to control its speed, according to the Texas Department of Public Safety, and set off a chain reaction that reached nine vehicles, including a 2013 Van Hool bus. Brandon Rogers, 48, of Texas City, was riding in the passenger seat of a BMW. He died at the scene. The BMW’s driver, 73, was taken to Memorial Hermann. Interstate 10 was closed for about six hours.

DPS identified the truck driver as Leandre Sime, 38, of Boca Raton, Florida. A Jefferson County grand jury indicted him on June 7, 2023, on a charge of criminally negligent homicide. He was arrested in January 2025, and his lawyer, Ryan Gertz, has said he intends to fight the charge at trial. An indictment is an accusation. Sime is presumed innocent.

Rogers’ family sued in the 60th District Court of Jefferson County, cause No. 23DCCV0514. The defendants include the motor carrier, DMG Consulting & Development Inc., which did business as Goldcoast Logistics Group, USDOT 2190975, and the broker, ArcherHub, which was added to the case on Jan. 31, 2025. ArcherHub denies negligence. The suit alleges who operated the truck and who selected the carrier, and a jury will decide those questions.

Disclosure: I’m a retained expert for the Rogers family in that case. Nothing in this piece comes from its discovery. Every fact here traces to a federal or state record, a public court docket, a news report, or the companies’ and founders’ own published words.

Why this one keeps pulling me back

I’ve written about this crash, this carrier and this broker since March. One side threatened takedowns, and the other pulled a story after a complaint. I’ve also had to correct my own work, in public, more than once. That’s the job. What survived the corrections is worse than what I got wrong, and it’s all sitting in free government databases that anyone selecting a carrier, writing a policy, or cashing a campaign check could have read.

Most carriers that land an out-of-service order fix the problem or close the doors and pay what they owe. Most trucking families that form several companies do it for ordinary reasons: a separate entity for equipment, another for real estate, a brokerage kept apart from the fleet. Lessors and banks sue businesses every day, and a closed docket can mean the bill got paid. No court has charged DMG’s owner, Dragos Sprinceana, with a crime, and no court has found him personally liable for his company’s debts. Giving to campaigns and attending political dinners is legal. Shortening your name is legal.

This story is about what happens when it all stacks up in one place, and who ends up holding the bill.

The man who owned the carrier

Dragos Sprinceana, born in 1979, came to the United States from Romania and built DMG Consulting & Development in the Chicago suburbs under the trade name Goldcoast Logistics Group. Its last MCS-150 before the crash, filed Sept. 29, 2022, reported 350 power units and 334 drivers, with Sprinceana as company officer, at 2130 Point Blvd., Suite 100, in Elgin, Illinois.

A Fresno County, California, court, ruling in June 2024 on a crash lawsuit, described his own deposition this way: he founded DMG, was the only person with management responsibility, and was its sole officer, director, and shareholder, with sole authority over distributions. The same ruling recounted his testimony that the company had no probationary period for new drivers, no logbook monitoring, and no one assigned to watch whether drivers followed federal safety rules. The court found enough to send the plaintiffs’ conscious-disregard and alter ego claims to trial and denied summary judgment. At a 350-truck fleet, there was no board to question, no compliance committee to subpoena and no vice president of safety to depose. There was Dragos.

He lived in Boca Raton, at 17686 Circle Pond Court, ZIP code 33496. Court papers in an equipment lease case in New Mexico, Inland PacLease v. DMG, 1:24-cv-00608, describe months of attempts to serve him: registered addresses that turned out to be virtual offices and executive suites, a fleet manager in Elgin who accepted papers because the owner was often not at the building, and finally court-approved alternative service. Family members filled the registered agent lines on the affiliated companies. Gherghina Sprinceana on GCG Logistics Inc., at virtual offices in Scottsdale and Ajo, Arizona. Gabriela Sprinceana, his wife, on Goldcoast Expediting Inc. in Romeoville and United Global Freight Inc., whose address moved to St. Charles, Illinois, in August 2024. Sprinceana himself on Goldcoast Financial LLC. A real estate company, 1425 Madeline Lane LLC, held the Elgin terminal. Goldcoast Carriers Inc. listed a man named Marian Visan. We’ll come back to him.

What the federal file showed on the day

On April 15, 2023, DMG’s number wasn’t under a federal out-of-service order. Its public FMCSA file that day already carried a closed enforcement case, IL-2021-0097-US1688, settled for $791,640 on May 17, 2022, 11 months before the crash. The violations cited were 49 CFR 383.37(a), knowingly allowing a driver to operate a commercial vehicle without a valid CDL, and 49 CFR 395.3(a)(3)(i), the driving-time limit. Under FMCSA’s definition, knowingly includes what a carrier should reasonably have known. Of the 11,946 closed FMCSA enforcement cases in the dataset I’ve analyzed, it’s the largest single settlement.

FMCSA’s crash file, as I pulled it Oct. 7, lists 150 crashes under DMG’s number from April 2016 to August 2024, with 10 people killed and 86 injured, in states from Maine to Texas. Before April 15, 2023, the count was 143 crashes and nine deaths.

The file has a shape, and the shape matters more than the total. Nineteen crashes in the earliest years. Twenty-five in 2020. Twenty-eight in 2021, the year FMCSA opened its first case. Then 44 in 2022, with three people killed, the year the first case closed with the settlement on the books. The penalty didn’t bend the line. The worst year came after the government had already looked.

The same trucks came back. One plate, 2910364, appears in an Oklahoma crash in May 2021, a month after FMCSA opened that first case. The truck went back on the road. On July 10, 2023, the same plate appears in a fatal crash at an intersection in Mount Holly Springs, Pennsylvania. That was 86 days after Brandon Rogers died, and 48 days before the government put the carrier out of service.

Everything above was in FMCSA’s free public systems before the truck on I-10 moved. On May 14, 2026, the Supreme Court held 9-0 in Montgomery v. Caribe Transport II that federal law doesn’t preempt a negligent selection claim against a freight broker. What a broker’s carrier file on DMG showed before that load moved, and whether a reasonable broker would have tendered it, is now a question a Jefferson County jury gets to ask. I’m not going to answer it in a newspaper.

After Beaumont

The file kept moving. FMCSA’s census shows a compliance review dated May 30, 2023, and an Unsatisfactory rating. The agency placed DMG out of service on Aug. 27, 2023, 134 days after Rogers died. On Sept. 12, 2023, a second, separate out-of-service order followed for failure to pay. A second enforcement case, IL-2023-0120-US1713, closed Oct. 19, 2023, for $97,990. It repeated the CDL and driving-time violations and added 49 CFR 382.215 for using a driver the carrier knew had tested positive for a controlled substance, and 392.2 for operating in violation of state or local law.

The two settlements total $889,630. A settlement in an FMCSA case is an agreement, not a payment. Whether the government collected any of it is the subject of a Freedom of Information Act request I filed. As far as the public record shows, it’s unpaid.

In September 2023, weeks after the first order, the Elgin terminal at 1425 Madeline Lane was sold in a sale-leaseback. The trucks didn’t stop. The crash file shows crashes under DMG’s number as late as August 2024, almost a year after the government ordered them off the road. The Illinois Workers’ Compensation Commission shows a worker hurt at a Goldcoast facility on Jan. 3, 2024, four months after the order.

Rocky

Early on Tuesday, Oct. 8, 2019, a tractor-trailer overturned on northbound Interstate 81 near Exit 296 by Strasburg, in Shenandoah County, Virginia. It hit a guardrail, then an embankment, then a bridge pillar. The driver, Chheanrem R. Chhean, 45, died at the scene. Virginia State Police said he was wearing his seat belt. The people who knew him called him Rocky. He drove for Goldcoast. As of March 2026, the Illinois Workers’ Compensation Commission and the company’s comp carrier told me no death claim had ever been filed for him.

Three years and 189 days separate Rocky’s death on I-81 from Brandon Rogers’ death on I-10. In between, the first federal case opened and closed, the crash count climbed, and the company kept running.

A registered agent is the person who accepts lawsuits, subpoenas, and government notices for a business. Illinois requires every corporation to keep one on file at a real address, so anyone with a claim has somewhere to deliver it. On March 21, 2025, someone filed Illinois Form BCA 5.10/5.20 for DMG Consulting & Development Inc., changing its registered agent from Dragos Sprinceana to Chheanrem Chhean, at 1425 Madeline Lane, the terminal the company had already sold. The form is signed under penalties of perjury. The signature line reads “CHHEANREM CHHEAN, PRESIDENT.”

Rocky had been dead five years and five months. He didn’t sign anything.

On Dec. 23, 2025, DMG filed its annual report. It lists Dragos Sprinceana as president and director, with Wellington and Boca Raton, Florida, addresses, and Aaron Gentry, also of Wellington, as secretary. The registered agent line didn’t change. Somebody filled in the officers and left the dead man in place.

I don’t know who typed that form. The Illinois file shows what it says and when it went in. What it does is plain. A lawsuit served on DMG through its registered agent goes to a man who died in 2019, at a building the company no longer controls. Every injured worker, every lessor, and every family suing the company starts by trying to find someone to hand the papers to. That search costs months and money, and the cost lands on whoever is suing.

The drivers on the paperwork

Rocky isn’t the only driver whose name ended up in the officer slot.

Goldcoast Carriers Inc., USDOT 3014047, lists Marian Visan as its president, secretary, and registered agent, and reported 325 power units on its last MCS-150. When DuPage County deputies went to Visan’s home in Lombard in August 2024 to serve papers for the lessor in the New Mexico case, a roommate told them he was an over-the-road truck driver and wouldn’t be back for two weeks, according to filings in that case. A company reporting more than 300 trucks to the federal government listed as its only officer a man his own roommate described as a working driver. Its Park Ridge office told a process server it no longer accepted service. Goldcoast Carriers’ crash file starts in March 2023 and shows 28 crashes and two deaths through December 2024. It has been out of service since Aug. 15, 2025.

Freight Transportation Group Inc., which does business as FTGI, USDOT 3008326, is the third number. Illinois lists it as file No. 71256391, and from 2017 into 2025 the state’s records named Anderson Taborda as its president, secretary, and sole director, with a registered agent whose professional profile lists him as director of operations at Goldcoast Carriers. Sprinceana’s name wasn’t on it. In a June 2025 media profile, he described Freight Transportation Group as one of his current transportation businesses. On Feb. 12, 2026, he signed an Illinois assumed-name filing as its CEO, under penalties of perjury, putting his name on a company he’d been calling his for at least eight months. FMCSA showed no federal insurance filing for FTGI and a 46.2% vehicle out-of-service rate in March. It has been out of service since April 20, 2026.

Three numbers, connected through the same people on the paperwork, all under federal orders today. Whether the later numbers picked up the equipment DMG could no longer run depends on vehicle records I haven’t finished pulling, and I’m not asserting it.

The money behind the trucks

The lien records show who was financing the fleet, and they show it wasn’t one fleet.

Starting in April 2017, a series of trust vehicles filed UCC financing statements against Sprinceana and his companies, all at 9300 Metcalf Ave. in Overland Park, Kansas, the headquarters of Shamrock Trading Corp., the parent of RTS Financial, one of the largest freight factors in the country: NOTARIUS 117 TRUST in 2017, VOLUNTAS 218 TRUST in 2018, MOTION 120 TRUST in 2020 and QUANTUM 222 TRUST in 2022. Between them, the filings reach Sprinceana, Gabriela and Gherghina Sprinceana, Marian Visan personally, and DMG, Goldcoast Carriers, GCG Logistics, United Global Freight, Goldcoast Expediting, Goldcoast Global Inc., Goldcoast Brokerage and Cargo 24 Inc. A factoring company advances cash against freight bills. These filings show one advancing against Goldcoast’s from 2017 onward, while the crash file grew.

On July 13, 2018, an Illinois UCC filing lists Pony Express Inc., at 638 N. Walnut Lane in Schaumburg, with VOLUNTAS 218 TRUST, the same trust holding liens on the Sprinceana companies, as secured party. FMCSA’s census lists Ioan Ursu as the officer of Pony Express Group Inc., USDOT 3938729, of Wheeling, Illinois. Ursu’s professional profile lists him as Goldcoast’s former chief operating officer. Sharing a factor isn’t a crime, and plenty of carriers in the Chicago suburbs share one. It does mean the two operations sat on the same financing five years before Goldcoast’s number went out of service.

In February 2024, six months after the first out-of-service order, the records show Compass Funding Solutions LLC of Clarendon Hills, Illinois, the factoring arm of Roy Dobrasinovic’s Compass Holding, taking assignment of the RTS lien position across DMG, Goldcoast Carriers, Goldcoast Expediting, United Global Freight, and Sprinceana and Visan personally. On Feb. 11, 2025, 18 months after the order, Goldcoast Carriers filed a new Compass-backed UCC. A financing statement isn’t a judgment and isn’t a default. It shows who held a claim on the trucks after the government told them to stop rolling. I’ve asked Compass whether it advanced money against successor freight bills after August 2023. It hasn’t answered.

One more filing belongs in any honest accounting. Illinois UCC file 029264910, dated Jan. 25, 2023, lists the debtor as Dragos Sprinceana, at the Boca Raton house, and the secured party as Dragos Sprinceana, at a commercial registered agent suite in Glendale, California. He filed a lien against himself. A perfected first-priority lien puts a claim on assets ahead of later judgment creditors. That one went in 80 days before Brandon Rogers died.

The creditors

The federal courts have 13 dockets with DMG, a Goldcoast entity or both as parties. Ten are closed. Three were open as of mid-September: Leaf Capital Funding in the Northern District of Illinois, 1:25-cv-07325, where the docket shows a default judgment on equipment finance; Inland Lease and Rental in New Mexico; and Centennial Bank in the Southern District of Florida, 1:25-cv-21270, an admiralty case filed March 18, 2025, against a vessel, the M/Y Olympus. Sprinceana’s June 2025 profile also touted a construction company he called Olympus Design and Development. The other federal dockets include Constellation NewEnergy over unpaid utilities, Equify Financial on equipment finance, and two cases brought by individual workers, Scott v. DMG and Thompson v. DMG.

The state courts add more. Palmer Leasing sued in Marion County, Indiana, in July 2023. Transport Enterprise Leasing sued in Cook County. Proventure Capital sued DMG, GCG Logistics, Goldcoast Expediting, Goldcoast Carriers and Sprinceana personally in Miami-Dade over a receivables agreement. MR Advance alleged in New York that Sprinceana personally guaranteed $2.7 million. Bank Capital Service documented 13 failed attempts to serve DMG and 11 to serve Sprinceana personally. A third case was closed because he couldn’t be located for service for 120 days. According to Romanian press reports on a July 2025 order by Judge Reid P. Scott, a Florida court examined how a Rolls-Royce ended up in his wife’s name. In October 2024, Sprinceana himself filed suit in Miami-Dade against Jacob Arabo, the jeweler known as Jacob the Jeweler, over two watches he said Arabo took to sell for him and never paid for.

Goldcoast also ran as a broker. Trans Recovery Solutions posted a public collection notice for unpaid freight charges owed by DMG, and Baxter Bailey & Associates lists it in its debtor database. The carriers who hauled for it and didn’t get paid are creditors too. They just don’t have a docket.

The table at Mar-a-Lago

While all of that was on file, Sprinceana was building something else.

In July 2020, he and Gabriela hosted a private gathering in South Florida for then-Rep. Matt Gaetz, according to the Romanian American outlet Tribuna. Federal Election Commission records list Sprinceana as president and CEO of Goldcoast Logistics Group and show contributions from the couple to the Republican National Committee, to Gaetz, and to Warrior Diplomat PAC, the leadership committee of then-Rep. Michael Waltz, from 2020 through 2024. Gabriela is listed in FEC filings as Goldcoast’s safety manager. The Waltz PAC checks include $3,400 on April 21, 2023, and $3,300 on May 6, 2024. The first came 11 months after the $791,640 settlement, and six days after Brandon Rogers died. One Democrat appeared on the list: $1,000 to Andy Thomson on Nov. 3, 2022.

His own published biography says he was with the team that celebrated the 2024 election result at Mar-a-Lago. On Jan. 13, 2025, a week before Waltz became national security adviser, Sprinceana posted that he had met Waltz at Mar-a-Lago and discussed Romania. On Feb. 13, 2025, he posted from Mar-a-Lago at a veterans event with Michael Flynn.

In April 2025, Romania’s then-prime minister, Marcel Ciolacu, said he had asked Sprinceana to explain Romania’s situation to the Trump administration, and said it wasn’t an official envoy role, according to Romanian national press. Ciolacu’s government later distanced itself from his public statements. On April 3, 2025, Sprinceana hosted a gala at Mar-a-Lago that he told the newspaper Gândul had about 700 guests, with then-Homeland Security Secretary Kristi Noem at his table. On Nov. 20, 2025, he posted that he had dined at Mar-a-Lago with Noem and Secret Service Director Sean Curran. That’s the latest the public record puts him at the club. It was 26 months after his career was ordered off the road, with the $889,630 still not shown as paid.

His vehicle for the Romania work wasn’t an FEC committee. Florida’s registry lists United Strategies of America Inc., a not-for-profit he incorporated June 13, 2022, at a Wellington mailbox address he later assigned to DMG. On May 16, 2025, an amended annual report removed his name. A search of the Justice Department’s Foreign Agents Registration Act database shows no registration for him, for United Strategies or for DMG. Whether any of his activity required one is a legal question this piece doesn’t answer.

None of that is illegal on its face, and none of it shows that any official knew who he was or did anything for him. It shows the order of events. The government found the violations, agreed on a number, and hasn’t shown it collected. The carrier number went out of service. The owner kept his seat at the table. My next installment follows the rest of the people at those tables.

The broker

ArcherHub is a Colorado company. It was formed on Jan. 22, 2014, as Archer Atlantic Global Logistics LLC, at an apartment at 1353 W. 88th Ave. in Thornton, with Darmanchev, Nick as organizer and registered agent, and renamed ArcherHub on March 2, 2020, by Articles of Amendment that list Nick Darmanchev as the filer. In a December 2019 FreightWaves profile, its founder described a Denver digital broker with about 500 customers, a fleet of its own trucks as a backup recovery plan, and an algorithm that “constantly looks for different trucks while the load is in transit.”

It also has a workforce in Moldova. When I reported in April, ArcherHub Moldova was listed on rabota.md and delucru.md, the country’s two main employment portals, as an employer with more than 200 employees in Chisinau, reachable at a +373 Moldovan number and at archerhub.office@gmail.com. Its postings advertised a freight broker agent, account manager, U.S. market operations lead, and after-hours dispatcher, all working American freight from Chisinau. Lucru.md describes the company as American. Both are true: the paper is in Denver, and a large share of the desk is in Chisinau.

The broker’s federal registration, USDOT 2345286, docket MC799497, was granted on Sept. 28, 2012, 16 months before the Colorado company that holds it existed. FMCSA’s census record for it, as I pulled it Oct. 7, lists the legal name ARCHERHUB at a Denver mail drop, 1500 N. Grant St., No. 5499, and lists no company officer, no telephone number, and no MCS-150 date. The MCS-150 is the form every registrant files to tell the government who runs it. The broker in a wrongful-death case has a federal registration that doesn’t name a person.

The paper behind the number keeps changing. FMCSA opened involuntary revocation proceedings against the broker authority five times, in March 2014, February 2019, May 2019, September 2019, and May 2024, and discontinued each after the required filing came back. On June 21, 2023, 67 days after the crash, the broker’s trust fund filing ended, and a Hudson Insurance Co. surety bond replaced it. In June 2024, after another proceeding opened, a new American Alternative Insurance Corp. bond replaced Hudson’s. Brokers change sureties daily for price and paperwork reasons. The number keeps running.

Colorado’s UCC index shows the lenders. BMO Harris Bank filed against Archer Atlantic Global Logistics in January 2019 and continued its filing on Aug. 4, 2023, 16 weeks after Beaumont. The U.S. Small Business Administration filed in September 2020 and continued in July 2025, still under the old company name, five years after the rename.

Two names

The founder has used two surnames on the record, and the record splits along them.

Alvys Inc., the Solana Beach, California, transportation software company that grew out of the brokerage, lists Nick Darman as its chief executive and a director in a March 31, 2026, state filing. It says it has raised $77 million, including a $40 million Series B in September 2025. In July 2020, ArcherHub’s own blog announced the Alvys carrier TMS to its carrier network. That lineage isn’t my inference. It’s their press. In a January 2024 interview with a Moldovan diaspora publication, he introduced himself as “Nick Darman (Nick Darmanchev),” a native of Chisinau who left Moldova in 1996.

In August, Alvys launched Foundry, a system that lets carriers and brokers build AI agents, including ones that monitor a carrier’s federal safety record and dispute entries. Darman told FreightWaves’ Thomas Wasson where the idea came from. He started a trucking company in 2004 while attending Georgia State, he said, and later found that drivers and owner-operators had used his signs, his DOT number and his authority without his consent. “I had no idea until a year later, when the DOT knocked on my door for an audit.” Unauthorized use of a carrier’s number is real, and a tool that catches it is a legitimate product. I’ve built one myself.

FMCSA has the audit. CDI Logistics LLC was formed in Georgia on Nov. 24, 2003, with Nikolay Darmanchev as registered agent at a house in Duluth, and got USDOT 1197492 in January 2004. The census lists Nikolay Darmanchev as its officer. It shows a review dated July 7, 2011, and an Unsatisfactory rating. Its insurer canceled in August, FMCSA revoked its authority Aug. 8, and the agency placed it out of service on Sept. 7, 2011. That order is still in force.

His August account spoke of “my DOT number,” singular. FMCSA’s census lists Nikolay Darmanchev as company officer of four motor carriers holding authority that summer, in four states. CDI in Georgia. Rodos Group LLC in Union Grove, Wisconsin, USDOT 1958313, authorized since 2009 and revoked Sept. 12, 2011, five days after CDI’s order. Archer Atlantic Freight LLC in Chicago, USDOT 2134480, whose authority FMCSA served June 14, 2011, 23 days before CDI’s review, listing nickd@archeratlantic.com. And Akindorf Auto Transport LLC in Aurora, Colorado, USDOT 2164528, formed June 16, 2011, which got its authority July 8, the day after CDI’s review. Earlier numbers under the same name in Pennsylvania date to 2002 and 2003. All of them are inactive today.

In 2017, the carrier side moved to North Carolina. HickoryTranz LLC was formed in Asheville with Nick Darmanchev as registered agent, over a signature reading Nikolay Darmanchev. North Carolina administratively dissolved it on Oct. 11, 2019. A year later, on Oct. 7, 2020, HickoryTranz filed a federal update listing 19 trucks, 19 drivers and Nick Darmanchev as officer. It was the carrier registered under his name when he told FreightWaves in 2019 that ArcherHub kept its own trucks as backup. FMCSA revoked its authority for the last time in June 2022.

A carrier owner can hold several companies for ordinary reasons. Nothing in the census says trucks or drivers moved from one number to another. The pattern regulators call a chameleon carrier is a new company standing up as an old one goes out of service, and whether this sequence is one is a question for FMCSA’s own files. The dates are the dates.

What the two names do to the record is plain. The Unsatisfactory rating, the out-of-service order, the revoked authorities and the crash files stay with Nikolay Darmanchev. The venture capital, the press and the product launch go to Nick Darman. The broker in the Beaumont case carries neither name. An investor checking Nick Darman finds a software CEO. A shipper checking ArcherHub finds an active authority and a bond. A juror reading about Nikolay Darmanchev finds a Georgia carrier that went out of service in 2011. Each is reading an accurate record. None is reading the whole one.

When he was asked

After the April 1 article ran, and after Yahoo picked it up, ArcherHub’s founder reached out to Freightwaves to say it wasn’t true. I answered the way I answer every subject: tell me where it’s wrong, and pick the time. I sent meeting invitations by email three times for dates and times he chose. He canceled all three on the day of the meeting, the day before, or days ahead. The article came down while it waited on his response. He never gave one on the record. Sprinceana’s representatives demanded that Parts One and Two come down. They didn’t. Neither man has answered the questions in this piece. The invitation stands for both.

What the rules already say

FMCSA wrote a rule for this in 2012. Under 49 CFR 386.73, the agency may order a carrier or broker out of service if it, or an officer, employee, agent or representative, operated under a new identity or as an affiliated entity to avoid an order, a penalty or association with a poor compliance record. The same section lets FMCSA merge a current company’s record with its previous incarnation. The public records for every number in this piece show no order under that section, and nothing in them says the agency ever looked.

Where Dalilah’s Law fits

H.R. 5688, Dalilah’s Law, cleared the House Transportation and Infrastructure Committee 35-26 on March 18, 2026, and has waited more than 200 days for a floor vote. It reaches the driver. Section 6 moves the consequence for knowingly using a driver without a valid CDL from a fine to the carrier’s registration, the same violation DMG settled twice. That’s a real change and the right one. It still binds the number, not the owner.

Section 7 bars FMCSA from registering brokers based outside the United States and, a year after enactment, bans carriers from using offshore dispatch services. ArcherHub is registered in Colorado, and neither ban reaches a U.S. broker’s own employees in Chisinau.

Nothing in the bill touches a registered agent who died in 2019, a carrier’s officer slot filled by working drivers, an unpaid penalty that stays with a dead number while its owner moves on, a broker registration that names no officer, or a founder whose federal file lists one surname and whose company lists another.

What would close it

None of this needs a new agency. FMCSA can require every MCS-150 to list every person who owns or controls a carrier or broker, every name each has used and every DOT number each has controlled in the past 10 years, under penalty of perjury, and check that list against its own out-of-service, Unsatisfactory and unpaid-penalty records before it grants or keeps authority. It can refuse to keep a registration active that names no officer. It can make an unpaid penalty follow the people who controlled the company that owes it, and it already has 386.73 to merge a record with its previous incarnation. States can reject a registered agent filing that names someone their own vital records list as dead. Campaigns can check a donor’s company against FMCSA’s out-of-service list before they cash the check.

Brokers and shippers can do the cheapest part for free. Before a load is tendered, pull the carrier’s enforcement history, its out-of-service record, and the names on its last MCS-150; ask for every officer’s prior names and prior DOT numbers, and write down that you did. It costs nothing, and it looks a lot better in a deposition than the alternative.

Brandon Rogers

Brandon Rogers was 48. He was riding in the passenger seat on a Saturday evening in Beaumont. Rocky Chhean was 45 and was in the cab of a truck on I-81. The second man’s name is on the corporate file of the company named in the first man’s lawsuit. The settled penalties haven’t been shown as paid. The owner’s last known dinner was at Mar-a-Lago. The broker’s federal file still names nobody.

The record was public before Brandon Rogers died. It’s still public now.

The crash report for this case can be found here

At 1:34 a.m. on July 5, a 2020 Freightliner Cascadia running for Big EL LLC hit the back of a Honda Accord on southbound Interstate 71 in Madison County, Ohio. The Ohio State Highway Patrol says the truck’s own dash camera showed it at 75 mph in a 70, with no roadway evidence that it braked. The truck crossed the median and stopped across all three northbound lanes. Tobias “Toby” Forsythe, 21, a goalkeeper headed to UMass Lowell, died at the scene. The patrol’s supplement says his blood alcohol content was 0.169 and that the Accord was traveling slowly. The patrol coded the truck for following too closely.

The driver

The driver was Bekhzod Asrarov, 42, of Maineville. The Department of Homeland Security told ABC6 he entered the country legally with a green card in 2024; Fox News Digital, citing sources, reported it came through the diversity visa lottery. ABC6 obtained records showing he earned his Ohio commercial license that fall. That detail matters more than most coverage gave it credit for. A green card holder who lives in Ohio gets a standard Ohio CDL, not a non-domiciled one. The state’s review of about 5,000 non-domiciled licenses would never have touched his.

Hours after the crash, Ohio State Highway Patrol inspector L. Grabovich put him out of service twice. He failed the English proficiency assessment, which, since June 2025, has been an out-of-service condition nationwide. His medical certificate had expired June 24, 11 days earlier. Both are things a carrier must check before dispatching a driver, under 49 CFR 391.11 and 391.41. The inspector couldn’t review his hours of service. “Driver was incarcerated,” the report says. Troopers seized the dash camera, three cell phones, and the electronic logging device. The load paperwork lists the shipper, the bill of lading, and the cargo as “unknown,” with Columbus as both origin and destination.

Troopers say he pulled the dash camera off its mount after the crash. It was found in his pocket. Court records cited by ABC6 show a charge of tampering with evidence, a third-degree felony in Ohio. ABC6 later reported he bonded out on a falsification charge, wears an ankle monitor, and that prosecutors said more charges could follow once reconstruction and toxicology are complete. Charges are allegations, and he is presumed innocent. Where he trained is not in any public record we found.

Run Big EL through a standard federal check on July 4, and it passes. Active authority, insurance on file, no out-of-service orders in the 24 months SAFER displays, two trucks and 205,284 miles declared. Its two out-of-service stops, in Arkansas in 2023 and Texas in 2024, had already aged off the screen.

The full file says more than the screen does. FMCSA’s inspection records show 14 roadside inspections of Big EL before the crash, starting in March 2023. Big EL hauled for Amazon in 2023 and 2024, for the U.S. Mail in October 2025, and out of Ford’s Kansas City Assembly Plant in March 2026. Two inspections took a Big EL truck out of service: one in Arkansas in May 2023 and another in Texas in January 2024. An Indiana inspection in April 2023 is flagged as post-accident, with no matching crash in the federal crash file. Then nothing. From March 2024 to October 2025, the file shows no inspections, a 19-month gap covering most of the year. Big EL reported 205,284 miles on two trucks.

Its insurance was $750,000 with Berkley Casualty, the federal minimum, set in 1980. Its one earlier crash was a three-vehicle tow-away in Laredo, Texas, in April 2023. Today its USDOT number is inactive, with an FMCSA enforcement entry dated July 23, 18 days after the crash.

That is the problem with checking one company at a time. The trouble is rarely in the company. It’s in the companies around it.

The owner

Big EL has one officer on file: Elyor Rustamov. Ohio’s records show he organized the company on Sept. 29, 2020, with a commercial registered-agent service in North Canton as its agent. FMCSA lists a Gmail address and a phone number with a San Diego area code.

The area code has a history. California’s Secretary of State shows Rustamov incorporated Elton Transport Inc. on April 14, 2017, at an apartment in La Mesa, outside San Diego, and named himself its agent. Later California records list him as the company’s chief executive, chief financial officer, secretary and director at 8176 Meeting Street, Apartment 107, in West Chester, Ohio. On Sept. 29, 2022, he signed Elton Transport’s dissolution as its director. For two years, he ran a California corporation and an Ohio trucking company simultaneously. No Elton Transport in the federal carrier file matches him.

Nothing in the public record accuses Rustamov of wrongdoing. Big EL kept one name, one officer, one address, and one MC number for six years. That is part of the point. The carrier looked stable. The paper around it moved.

The street

Snider Cove Way is a residential street in Mason with 38 addresses. Federal records list four trucking companies on it, declaring 78 trucks.

Hebron Trucking LLC, 5934. Formed March 17, 2023, by Tukhfa Mukhriddinova, with its agent at an apartment on South Legare Court in West Chester. It obtained its USDOT number on Dec. 27, 2024. Today it declares 50 trucks, 55 drivers, and 3,112,666 miles, insured for $750,000 with Trisura Specialty. Federal inspectors have looked at it 33 times since it registered, five times with an out-of-service order. Thirty-two different tractors and trailers have been inspected under its number. Five came from Schneider’s used fleet, which is how small carriers normally buy trucks. One came from Big EL: VIN ending 4994, under Big EL in Kentucky in October 2025 and under Hebron by March 2026.

YWT LLC, 5925. An Indiana company. It registered with FMCSA on June 16, 2025, and declares 25 trucks and 3,116,666 miles, within 4,000 miles of Hebron’s figure. Federal inspectors have stopped its trucks five times. It didn’t register to do business in Ohio until June 17, 2026, a year after it started running, with an agent in Maineville named Akbar Ismatov. On Aug. 11 its agent became Rashid Johnson, at 5925 Snider Cove Way. FMCSA now lists Johnson as YWT’s officer.

Premier Truck Group LLC, 5927. Registered with FMCSA in September 2023 with one truck, officer Barno Abidkhodjaeva. She signed its certificate of dissolution on Nov. 29, 2024. Her name didn’t leave trucking. Ohio lien records tie her to Premier Trucking Group Inc., a Cincinnati carrier with 86 trucks, 88 drivers and 8.9 million miles, whose federal officer is Sam Avazov. A 2021 lien named her and that company together and listed her at 5927 Snider Cove Way. Premier Trucking Group Inc. has been inspected 190 times since January 2024, 42 times with an out-of-service order, and has 10 crashes on file.

Big EL, 5948. Two trucks. One dead goalkeeper.

The neighbors

Trucking runs on factoring. A small carrier sells its unpaid freight bills to a finance company for cash this week instead of in 45 days, and the factor files a lien to lock in its claim. Liens are public, and they show who is doing business with whom, and when.

On Jan. 8, 2026, Hebron and Mukhriddinova were named as debtors in a lien for Fortis 126 Trust. The next day, Abidkhodjaeva and Premier Trucking Group Inc. were named in one for the same trust. Fortis 126 Trust’s address is 9300 Metcalf Ave. in Overland Park, Kansas, the headquarters of RTS Financial, one of the largest trucking factors in the country. The same address appears on liens for sibling trusts with the same naming pattern: Grandis 125 Trust and, at 9350 Metcalf, Quantum 222 Trust.

Then Hebron switched. At 8:12 a.m. on Feb. 20, 2026, the Fortis lien was terminated. At 8:16 a.m., First Corporate Solutions, filing as a representative for an unnamed secured party, recorded a new lien on all of Hebron’s assets, including its freight receivables. Three days earlier, the 2021 lien naming Abidkhodjaeva was also terminated.

First Corporate Solutions has been here before. On Feb. 9, 2022, it filed a lien against The Greatest Generation LLC. On March 24, 2022, an amendment added a second debtor name: “Hebron Trucking.”

The money

Trucking runs on factoring. A small carrier sells its unpaid freight bills to a finance company for cash this week instead of in 45 days, and the factor files a lien to lock in its claim. Liens are public, and they show who is doing business with whom, and when. On Jan. 8, 2026, Hebron and Mukhriddinova were named as debtors in a lien for Fortis 126 Trust. The next day, Abidkhodjaeva and Premier Trucking Group Inc. were named in one for the same trust. Fortis 126 Trust’s address is 9300 Metcalf Ave. in Overland Park, Kansas, the headquarters of RTS Financial, one of the largest trucking factors in the country. The same address appears on liens for sibling trusts with the same naming pattern: Grandis 125 Trust and, at 9350 Metcalf, Quantum 222 Trust. Then Hebron switched. At 8:12 a.m. on Feb. 20, 2026, the Fortis lien was terminated. At 8:16 a.m., First Corporate Solutions, filing as a representative for an unnamed secured party, recorded a new lien on all of Hebron’s assets, including its freight receivables. Three days earlier, the 2021 lien naming Abidkhodjaeva was also terminated. First Corporate Solutions has been here before. On Feb. 9, 2022, it filed a lien against The Greatest Generation LLC. On March 24, 2022, an amendment added a second debtor name: “Hebron Trucking.”

The house

Then the house at 5934 Snider Cove Way turned out to have a longer history than the carrier using it.

In 2020, a man named Marufjon Sayfullaev formed The Greatest Generation LLC in West Chester, Ohio. It registered with the FMCSA as Hebron Trucking. In July 2021, one of its trucks was in a crash in Balch Springs, Texas, that killed two people. In March 2023, FMCSA revoked its operating authority, 12 days after a different company, Hebron Trucking LLC, was formed in Ohio by a different person.

A year later, on March 23, 2024, The Greatest Generation filed an amendment with the state of Ohio changing its name to Turan CDL School LLC. Three days after that, under the Turan name, it moved its registered agent address to 5934 Snider Cove Way. On April 8, it changed its name back. The next day, Sayfullaev formed a new company, Turan CDL School Inc., with its registered agent at the same house.

Turan CDL School is the Middletown school that federal regulators later moved to remove from the national training registry, and that Fox News Digital reported had advertised training to Uzbek speakers.

In December 2024, Hebron Trucking LLC took out its USDOT number at 5934 Snider Cove Way. On May 14, 2025, Ohio recorded two changes that day: the school’s registered agent address moved out of the house, and Hebron Trucking LLC’s moved in.

And on July 21, 2026, 16 days after the crash and five days after the federal government announced it was sending Homeland Security Investigations after CDL schools, Ohio recorded two more changes that day. Sayfullaev was replaced as The Greatest Generation’s registered agent. Turan’s registered agent was replaced too.

Here is what that does not prove. Hebron Trucking LLC’s federal officer is not Sayfullaev. The two companies share no phone number on file, and the federal inspection file holds no truck records for The Greatest Generation to compare. Big EL has no filing tie to Turan. A shared house and a shared trade name are not proof that anyone controls anything. They are exactly the affiliation factors federal regulations tell investigators to examine, and none of it is visible on any single company’s federal record.

Meeting Street

Every thread in this story runs back to one street in West Chester. Federal records list 35 motor carriers at Meeting Street addresses there, almost all of them apartment units.

The Greatest Generation’s articles of organization, filed Feb. 17, 2020, put Sayfullaev’s agent address at 8173 Meeting St., Apartment 110. Its federal address is 8171 Meeting St., Apartment 126. It declared six trucks. FMCSA moved to revoke its authority in November 2021, then discontinued that a month later, a sequence that usually means an insurance lapse fixed in time. In July 2021, one of its trucks was in a crash in Balch Springs, Texas, that killed two people and injured one. The revocation that stuck came March 29, 2023.

Apartment 126 didn’t go quiet. On Feb. 4 and Feb. 5, 2025, two more carriers registered there on back-to-back days: Shox Transport LLC and Elyor Trucking LLC, one truck each, different officers, zero miles declared. Big EL’s owner shows up on the same street in California’s records, at 8176 Meeting St., Apartment 107. Hebron’s founder started three miles away on South Legare Court.

On July 21, 2026, Ohio replaced Sayfullaev as The Greatest Generation’s agent with Sherzod Namuradov of Loveland. The same day, Turan CDL School Inc.’s agent, who by then was Sherali Butunboev, was replaced by Farrukh Kholmukhamedov. None of these people is accused of anything. They are the names on the paper, and the paper moved after the crash.

The equipment

The tractor that hit Toby Forsythe, VIN ending 2369, first shows up in the federal file in October 2024 under MAZ Express LLC of Cumming, Georgia, an eight-truck carrier, on Ohio plate PWR1726. By January 2026, it was running for Big EL on Ohio plate PXB8066.

The tractor from Big EL’s 2023 Laredo crash, on Ohio plate PWT7781, turned up under Borderlanders Inc. of Pittsburgh in October 2024, then under UMT Global Logistics of Naperville, Illinois, from June 2025 through January 2026, still wearing the same Ohio plate. UMT declares 110 trucks, 140 drivers, and 35.5 million miles, and has 42 crashes on file. Plates usually follow the owner, not the truck. A plate that rides across three carriers is the kind of thing an investigator writes down.

The trailer Big EL was pulling on July 5, VIN ending 4055 on Maine plates, was inspected under Borderlanders 13 months earlier. Three more Big EL trailers cycled through Successor Inc. of Wilmington, Delaware.

Borderlanders was incorporated in Pennsylvania on Sept. 24, 2018. Its president is Farrukhjon Akramov. It changed its registered office on Feb. 9, 2019, the same day FMCSA issued its USDOT number. It declares 109 trucks and 115 drivers, has been inspected 896 times since January 2024 with 124 out-of-service orders, and has 80 crashes on file since 2020, four of them fatal. FMCSA served it a notice of involuntary suspension effective Oct. 14. Its federal address, physical and mailing, is Suite 200 at 322 N. Shore Drive, a Regus business center that rents virtual offices from $179 a month. Sixteen other carriers list the same suite. Its phone number carries a central Pennsylvania area code, not Pittsburgh’s.

Successor Inc. lists Suite 1200 at 1000 N. West St. in Wilmington, an address 15 carriers share. Its officer, Azizbek Kaharov, is also an officer of Zeus Freight & Analytics Corp., a freight broker in Short Hills, New Jersey. Successor declares 70 trucks but only 42 drivers, has been inspected 324 times since January 2024 with 52 out-of-service orders, and has 16 crashes on file.

Borderlanders and Successor share 99 pieces of equipment in the federal file, 26 tractors and 73 trailers, with no common officer, phone or address on file. Trailers move through leasing pools. Tractors don’t, not 26 of them.

How we found it

None of this came from a SAFER check, and none of it came from one database.

I built

Tea Technologies

to cross-reference the FMCSA carrier census, authority history, insurance filings, inspections, violations and crashes against the equipment itself, every VIN and plate captured at every roadside stop, and then against the records that live outside FMCSA like the PPP/EIDL, Sanction lists from dozens of countries, the Training Provider Registry, ELD registrations, pandemic loan records, Census demographics, SEC, FBI, PHMSA, state corporate and lien filings, and the list goes on. More than 40 datasets in all. The question it asks is not “is this carrier clean?” It’s “who is this carrier connected to, and what are they carrying?”

That’s why it sees things before a crash makes them news. The Big EL tractor moved to a neighbor’s authority in March, four months before I-71. The Greatest Generation wore a CDL school’s name in 2024, two years before anyone in Washington said the word, Turan. The signals were in public records the whole time. They were just in different buildings. No other system draws on the volume of data ours does across datasets, departments, and agencies. Some comeptitors ot the product actually joked, “He’s got way too much in there.” Well, we’re about predictive data and ensuring clients understand the full risk exposure they're adopting when they insure or use a broker, carrier, insurance provider, or shipper, etc., not just vetting and adding a name and phone number.

We’ve done this before. In March, four months before this crash, I published “California’s CDL fraud factory,” tracing a CDL bribery scheme that ended in prison sentences to a network still operating under new names, by matching Training Provider Registry entries to state corporate filings, liens, phones, addresses and VINs. Earlier in this series, the same method mapped a relay network of 23 USDOT numbers sharing tractors with no common officer, phone, or address on file, which drew 5,015 roadside stops with violations, and found 946 carriers that FMCSA had placed out of service since July 2024, never rescinded, and that were inspected again anyway, 1,591 times.

We’ve led to over 40 solved cases that were stuck before the agency and feds used our system and me to help solve some of their more difficult cases.

What the government did with my data

The government was already moving on CDL schools before July 5. In December 2025, the Department of Transportation removed nearly 3,000 providers from the Training Provider Registry. Then I-71 happened.

On July 12, a week after the crash, FMCSA asked us for help with entry-level driver training schools. That afternoon we delivered ranked target lists covering 3,981 training providers, cross-referenced against carriers, equipment, crashes, sanctions and loan data, organized by ZIP code and mapped into field routes. The next day, FMCSA’s enforcement office and its special investigations team asked to work through the lists with us against their own.

On July 16, the Departments of Transportation and Homeland Security announced that Homeland Security Investigations would help investigate CDL schools suspected of fraud. By Aug. 31, FMCSA had removed more than 110 training providers from its registry, linked to more than 5,000 drivers who had failed English proficiency tests, and the Justice Department had formed a multistate task force with more than 1,000 fraud leads. Turan was among the schools in our data. FMCSA has moved to remove it.

Investigators do the door knocks and make the calls, and they did their own work on each one. Our part was the map. Friday night at the Truck Safety Coalition gala, in a room full of families who have buried someone after a truck crash, FMCSA Administrator Derek Barrs called me the data man. I’ll take that. I work 120 hours a week, and I devote untold hours to solving these issues in our industry because it's about safer highways, but it's also about the economic damage this costs our country, our families, and the carriers, brokers, and drivers trying to do it right. I do not bill my time, and I charge $10k for six months of access that costs me $60k in data. We’re not here for the money. We’re here to keep people alive. By the end of the year, our hope is to make our system open source. Free to everybody.

What would fix it

Every one of these links was public. None of them was connected. Three changes would connect them.

First, put equipment on the carrier record. FMCSA captures every VIN and plate at every inspection. A tractor moving between USDOT numbers on the same street should flag automatically.

Second, read the states. Name changes, agent changes, and amendments filed weeks apart are where reincarnation hides, and they live in 50 Secretary of State databases nobody in the federal system is reading.

Third, use the rule on the books. Congress strengthened FMCSA’s power in 2012 to consolidate records of affiliated carriers and revoke those built to dodge a bad history. A transportation defense firm wrote this June that enforcement of it has been “essentially nonexistent.”

Toby Forsythe started every game in goal for Shawnee State last year. The truck that hit him belonged to a company with a clean-looking record, on a street where the paperwork ran in circles.

The record looked clean. The network didn’t. There is no reason we can’t solve these issues from apredictive posture vs a reactive one. We can analyze data in ways that tell us where vehicles are likely to move next when you close a chameleon carrier down. We literally have shelved data for shelved entities that are sitting and waiting to just throw equipment on them when the dead entity is closed.

www.dotcensuslive.com

is another site you can monitor DOT census and authority changes and applications in almost real time.

Disclosure: Tea Technologies, which I founded, provides data and advisory services to FMCSA and various state and federal agencies.

As DNA and technology continued to develop, so did our constant resourcing of materials. I went on to file for my legal emancipation from my grandparents at 15, and to our knowledge, I’m the only successful one to do that in VA. Those decades of historical York County, VA, paper record deep dives, the AOL floppy internet access, and tech development led me to find families all over the world, to reunite with tech, no tech, DNA, and no DNA. We knew where the source data was and where it was constantly evolving, and that got us here to where we are today.

That bled into trucking... decades ago with the ICC, the FHWA, and then the FMCSA, insurance policy, and litigation. I started as a driver, then became a broker, then a manager, then an owner, then a large-fleet executive, and now we’re here: litigation, risk, and insurance. We’re the best at it because we’ve spent our entire lives developing data that solves the general unknown, often blank-white puzzle.

Chameleons aren't new; going back to 2008 and the Sherman bus crash, we’ve been here before. Many times. From Sherman to the Congressional Archi and the subsequent Ursa push to solve it, to where we are today, the buck never really stops; it just keeps getting passed, with ebbs and flows of outrage when bodies drop. So what is it? We tried to break it down in our 60 Minutes piece, and in other work we do with just about everybody, but this is the 101 for dummies: from their development to their quick rise, sudden fall, and reincarnation. It all boils down to identity, disclosure, and accountability.

A federal rule lets you identify the person responsible for a truck. Every interstate carrier files an MCS-150 that names its company officers. Every for-hire carrier designates a process agent in every state it runs, on a form called the BOC-3, so a lawsuit can be delivered anywhere the truck goes. Every corporation keeps a registered agent with its secretary of state for the same reason. Federal law also requires an applicant for operating authority to disclose “any relationship involving common ownership, common management, common control, or common familial relationship” with any other carrier, broker, or freight forwarder in the three years before it applies.

Put together, that is the promise. A DOT number is a name, an address, and a person, and the crash file, the enforcement case, and the unpaid penalty follow that number to the people behind it.

A chameleon carrier is the business built to break that promise. Same trucks, same drivers, same dispatch floor, new paper. The industry calls it authority reincarnation, and the regulators’ own word for the target is “a new identity.”

Why I went back

On Feb. 8 I published a piece on how these networks build their empires, after a truck in the Sam Express orbit crossed the centerline on State Road 67 in Jay County, Indiana, and killed Henry Eicher, 50, his sons Menno, 25, and Paul, 19, and their friend Simon Girod, 23. That piece walked the growth formula. Since then I’ve spent eight months in the records behind it, and in a federal courtroom’s worth of complaints filed by drivers, insurers, and carriers caught in the same machinery. The pattern beneath it all isn’t the trucks. It’s the identity.

You can’t judge a trucking entity the same way Nick Shirley judges a day care. If there are no kids, there's clearly no day care. If there are no trucks, that doesn’t always mean what you think it means; M&A fleets have some of the same chameleon indicators as chameleon fleets, as do Driveaway fleets and leasing fleets like Ryder and Penske. What decides is where you fall on what I call the chameleon spectrum, and that takes work.

The topline

The government has known the size of this since 2012. The Government Accountability Office matched new applicants against carriers with history, using company names, addresses, and phone numbers, and found carriers with chameleon attributes rising from 759 in 2005 to 1,136 in 2010, 5,640 over six years. About 94% were freight carriers. The key finding: “18 percent of the applicants with chameleon attributes were involved in severe crashes compared with 6 percent of new applicants without chameleon attributes.” Three times the severe-crash rate. At the time, FMCSA’s vetting program screened only passenger and household goods carriers, about 2% of new applicants in 2010. The agency expanded vetting to all new applicants in February 2016.

Ten years later, the agency says the problem got bigger. When Transportation Secretary Sean Duffy launched FMCSA’s new registration system, Motus, on May 19, 2026, the department said “several thousand suspicious registration numbers” were “tied to fraudulent carriers,” and described the old system this way: “All they needed was an email, name, and physical address.” A year earlier, when FMCSA started checking applicants’ identities against government IDs, the agency’s registration director, Ken Riddle, said, “Fraud is rampant.” In February, Duffy said, “You can’t have 200 DOT numbers going to a P.O. box.”

This is an M&A, private-equity-backed fleet, versus a Chameleon-indicated fleet ownership model. The M&A/PE-backed holding company model discloses and manages the fleet as a true, identifiable business that can be held accountable, while the Chameleon-indicated fleet and owner declare they know nothing about each other and often claim they're totally unaffiliated.

Most of what follows can be innocent on its own. Families run several companies. A brokerage and a fleet under common ownership is an ordinary structure. Carriers share office buildings, buy each other’s used trucks, lease from the same lessor and use the same factoring company. Immigrant communities have built trucking companies the way every other community has, through mentors, relatives, and people from the same town who already knew how to file the paperwork. None of that is fraud, and nothing in this piece says it is.

The problem starts when you line up the records, and the identity doesn’t hold still.

What the rules say

Federal law is more specific than most people in this industry realize. Under 49 U.S.C. 13902(a)(1)(C), an applicant for authority must disclose its relationships of common ownership, management, control, or family with other carriers, brokers, and forwarders over the prior three years. Under 13905(d)(2), FMCSA may revoke a registration for failing to disclose a material fact or a relationship with a carrier the agency finds “unwilling or unable to comply.” Since 2012, 49 U.S.C. 31135(b)(1) has said that two or more carriers or persons “shall not use common ownership, common management, common control, or common familial relationship to enable any or all such motor carriers, employers, or persons to avoid compliance, or mask or otherwise conceal non-compliance, or a history of non-compliance,” and the statute lets the agency go after an officer individually.

The enforcement tool is 49 CFR 386.73, adopted in 2012. It lets FMCSA order a carrier, broker, or forwarder out of service if it “operated or attempted to operate” under “a new identity or as an affiliated entity” to avoid an order, a penalty, an enforcement action, or being “linked with a negative compliance history.” The test is “substantial continuity between the entities such that one is merely a continuation of the other,” and the listed factors read like an investigator’s checklist: “commonality of officers and management personnel,” “identity of physical or mailing addresses, telephone, fax numbers, or email addresses,” “identity of motor vehicle equipment,” and continuity of insurance, drivers, and customers.

The form that was supposed to collect the affiliation answer up front is the MCSA-1. Its Section K asks applicants to “disclose certain information concerning affiliations with other entities registered with FMCSA.” The rule that created that registration system was published in October 2015, and FMCSA suspended it for existing carriers effective Jan. 14, 2017. The public record doesn’t show whether new applicants have been held to the affiliation question since then. The MCS-150, which most carriers still file every two years, asks for officers. It doesn’t ask for affiliates, prior names, or prior DOT numbers.

That is the agency’s own architecture. The law requires the disclosure. The registration rule built around the form has been suspended for existing carriers since 2017. The records that follow show what fills that space.

Indicator one: who is the officer

The first question on any carrier is the simplest one: who runs it. The records keep answering with people who can’t be found, can’t be the operator, or aren’t there at all.

A dead man is the starkest version. On March 21, 2025, someone filed an Illinois form naming Chheanrem Chhean as registered agent for DMG Consulting & Development Inc., the company that did business as Goldcoast Logistics Group, with a signature line reading “CHHEANREM CHHEAN, PRESIDENT.” Chhean, a truck driver everyone called Rocky, died on Interstate 81 in Virginia on Oct. 8, 2019. The company’s December 2025 annual report still listed him.

A working driver is next. Marian Visan is the sole officer of record for Goldcoast Carriers Inc., USDOT 3014047, which reported 325 power units and 330 drivers on its last MCS-150. In August 2024, according to court papers in a New Mexico equipment lease case, DuPage County deputies trying to serve him at home were told by his roommate that he was an over-the-road truck driver who wouldn’t be back for two weeks.

Nobody at all is the third. FMCSA’s census record for ArcherHub, USDOT 2345286, the Denver broker named in the Beaumont wrongful-death case I’ve covered this year, lists no company officer, no phone number, and no MCS-150 date. The broker authority has been granted, revoked, reinstated, and pulled back from five revocation proceedings. The record doesn’t name a person.

Then there is the person with two names. The founder behind that brokerage files Colorado and North Carolina paperwork as Nick Darmanchev or Nikolay Darmanchev, while his venture-backed software company’s California filings list him as Nick Darman. Every Unsatisfactory rating and out-of-service order in his file sits under the longer name. That’s legal. It’s also why a search under one name never finds the other.

The officer field is where 386.73 starts. “Commonality of officers and management personnel” is the first factor in the rule. A registration that names a dead man, a long-haul driver, or no one has already defeated it.

Indicator two: what the company says about itself

The second family of indicators is disclosure: what a carrier tells the government about its size, its equipment and its relationships, and whether that matches what shows up at the scale house.

Floyd Inc. is the textbook case in a public court file. In a federal suit filed May 23, 2023, MS Amlin, a Lloyd’s syndicate, said Floyd’s June 24, 2022, insurance proposal declared 12 tractors, its Dec. 16, 2022, MCS-150 reported 112 power units, and the policy covered at least 81 tractors. The insurer sought to rescind the policy. The case settled and closed Aug. 2, 2024. In a deposition taken April 7, 2025, and filed publicly in another case, Floyd’s chief executive, Aleksandar Mimic, testified that he runs both Floyd and Super Ego Holding, and that Super Ego holds no operating authority of its own.

Mileage tells the same story from the other direction. Leader Freight Systems Inc., USDOT 3283188, an Indianapolis carrier whose officer of record is Danilo Tosic, filed an MCS-150 on Feb. 9, 2026, reporting 13,596,399 miles for 2023. The same filing reports five power units. Five trucks don’t run 13.6 million miles in a year. The fleet that ran them went somewhere.

Names drift too. FMCSA’s census lists Davenport, Iowa, carrier Denver Cargo Inc., USDOT 3585416, as doing business as LEADER FREIGHT SYSTEM. Iowa records show Denver Cargo adopted that name on Nov. 12, 2024. About 17 weeks later, FMCSA revoked Leader Freight Systems’ operating authority, effective March 10, 2025. It was reinstated April 8. No sale document, lease assignment or UCC filing I have connects the two companies, and I’m not asserting one. The record shows one company’s name moving onto another company’s federal file while the first company’s federal file fell to five trucks.

Under the law, the carrier must provide the declaration. The carrier files the MCS-150 under its own signature, and the affiliation disclosure is an obligation, not a courtesy. A broker or insurer who reads the declaration and never checks it against inspection records is reading the one part of the file the carrier wrote.

Indicator three: whether anyone can find them

The third family is accountability, where identity failures turn into money and time taken from people with claims.

When National Specialty Insurance Co. filed an interpleader over Hope Trans LLC in federal court in Dallas in October 2025, the insurer needed to serve the company’s alleged former owners. A process server went to their Orlando home four times between Dec. 1 and Dec. 12, 2025, three mornings and one evening, with their names on the call box and a vehicle in the driveway. Nobody answered. On Jan. 23, 2026, a magistrate judge authorized taping the papers to the door. In a cargo-theft RICO case in Miami in 2022, Scotlynn USA Division’s process server returned four summonses unexecuted.

The federal side breaks the same way. FMCSA’s process-agent policy, MC-RS-2019-0002, gives a carrier with an invalid BOC-3 a show-cause order and 30 days to fix it before the agency can suspend its authority. Revocation proceedings for lapsed filings are routine, and most get discontinued when the filing comes back. Denver Cargo’s licensing file shows seven involuntary revocation proceedings since December 2021, every one discontinued. Leader Freight’s shows seven more, all discontinued, plus the March 2025 revocation and a reinstatement four weeks later.

Each one shows the paper was out of order. None of them finds who controls the trucks.

The money breaks last. A penalty FMCSA settles binds the number that settled it. DMG settled two federal enforcement cases for $889,630, by FMCSA’s records, and its number went out of service. Whether the penalties were collected is the subject of a FOIA request I filed. The out-of-service order doesn’t follow the people who controlled DMG to the next number. The statute that would let FMCSA go after an officer individually has been on the books since 2012.

Indicator four: how fast it grew

The fourth family is growth, and it’s the one brokers notice first and understand last.

FMCSA’s own audit schedule gives a new carrier a year of running before anyone from the government shows up. Federal law requires a safety audit within 12 months of a new entrant beginning operations, and the agency monitors new entrants for 18 months. In fiscal 2023, FMCSA reported 60,138 new-entrant safety audits, 50.6% completed on time. A carrier that goes from a handful of trucks to hundreds inside that window is running on paper nobody has checked.

The Indiana network did exactly that. When FMCSA shut down carriers tied to the Jay County crash in February and March 2026, trade press reported KG Line Group at 310 power units, Tutash Express at 156 and AJ Partners at 111. Floyd went from 12 declared tractors to 112 power units in six months. Suplicium Transport, which I reported on in June, had operating authority 14 weeks old when its truck crashed, declared one truck, and showed 675 VINs in federal inspection records.

Nobody builds a 300-truck fleet in a year out of savings. The capital, the trucks, the insurance, the dispatch floor, and the drivers come from somewhere, and in the networks I’ve documented, they come from people who did it before.

It isn’t one company. It’s a method.

Time it here has been based with different officers in OH, then to IL, then to OH, then a supposed sale in April where the officer went blank in FMCSA, then the officer reappeared back on the filing with FMCSA but ended up in Florida with a new email and fewer trucks. Timeit’s sister entities kept the same migratory official, address, phone, and email patterns.

Civil courts have started saying so. On Sept. 23, 2026, six carriers, including Stevens Trucking, Western Flyer Express, and Freymiller, sued C.H. Robinson and Total Quality Logistics under the federal racketeering statute in the Eastern District of Texas (Case No. 2:26-cv-00869). The complaint alleges that Super Ego Holding “holds no motor carrier authority of its own” and operates through more than 70 carrier entities, with more than 1,500 equipment transfers between affiliated DOT numbers. It quotes a dispatcher’s text to a driver: “Super Ego Holding is a mother company, we have several daughter companies… those are all our companies.” The defendants haven’t answered, and those are allegations.

The driver class action against Super Ego, Atkinson v. Super Ego Holding, filed in Chicago federal court on Aug. 5, 2022, alleges the affiliated carriers operated as “alter egos,” with drivers assigned loads for entities other than the one they’d signed a lease with, and that the companies “fraudulently altered load confirmation documents.” More than 800 drivers have joined it. In February 2023, North River Insurance Co. sued Super Ego Holding and United Ego LLC in DuPage County to void four policies, alleging insurance fraud. None of those claims have been decided against anyone.

Disclosure: I’ve been retained by plaintiffs in cases against Super Ego entities. Everything here about Super Ego comes from public filings, not discovery in any of those cases.

The ecosystem behind the growth

The question I get most from brokers is how a first-time owner gets to 300 trucks. The answer in Chicago’s Balkan trucking community, which I’ve called the EuroChicago model, is that he doesn’t do it alone. He does it with a mentor who has already built the factoring company, insurance program, truck rental fleet, fuel card, and office suites.

Compass Holding, founded by Radovan “Roy” Dobrasinovic, provides that infrastructure for much of that community. Its companies include a factoring business, a truck rental and leasing company that reports 1,800 power units to FMCSA, a payment and fuel card company, a risk retention group, and a carrier, Compass Logistics LLC, at 115 55th St. in Clarendon Hills, Illinois. FMCSA’s census shows four more carriers registered in that building since November 2023, each with a different officer, in suites 401 through 410: LVA Expedite, NNK Express, VS Express and Major Line.

Filip Milivojevic’s path runs through it. His 2020 federal campaign contribution records list his employer as Compass Payment Services, where he worked as a national account manager. On March 10, 2021, he incorporated Denver Cargo in Davenport, Iowa, and FMCSA added it to the registry that day; it received operating authority on April 16, 2021. On LinkedIn, he wrote, “I started my carrier with my mentor, Roy,” tagging Dobrasinovic. Denver Cargo reports 45 power units today, and FMCSA’s crash file shows 36 crashes under its number, with two people killed.

The relationships are in the state registries. Illinois Articles of Organization filed June 25, 2025, for Joint Venture FH, LLC list two managers: Roy Dobrasinovic, at Compass’s Clarendon Hills address, and Filip Milivojevic. Illinois Articles filed Dec. 14, 2021, for Panda Truck Sales LLC list three managers: Maybach Capital, Filip Milivojevic and Nenad Balac. Maybach International Group, USDOT 2487790, reports 296 power units, and FMCSA’s crash file shows 193 crashes under its number. In 2025 and 2026 filings, Panda’s managers were cut to Maybach Capital alone. In February 2025, Denver Cargo gave $50,000 to the Serbian American PAC, FEC committee C00895003, one of five $50,000 founding contributions.

Equipment moves through the same circle. FMCSA inspection records show a tractor with VIN ending 469514 inspected under Denver Cargo and under two carriers named as defendants alongside Super Ego in the Atkinson case, Twin Carrier and Trytime. A shared VIN can be a sale, and one truck proves nothing about control.

None of this shows anyone did anything illegal. Mentorship is how this industry has always grown. What the records show is the infrastructure a new carrier needs to scale, available in one building, from people who have done it before, to people who learn it from them. That’s the part the federal registration system never sees. The MCS-150 asks for one carrier’s officers. It doesn’t ask who financed the trucks, who insures the fleet, who taught the owner how to file, or which suite down the hall opened its authority last month.

How it works, start to finish

Strip out the names, and the method is short. You learn the paperwork from someone who already filed it. You form a company and get a DOT number the same week. You lease the trucks, factor the invoices, and buy the insurance from the same circle. You put a relative, a driver, or a registered agent service in the officer slot, or leave it empty. You grow as fast as brokers will tender loads, because no auditor is coming for a year. When the crashes and the violations pile up on the number, you let the filings lapse, and the next number, under a new company name, picks up the trucks. If someone sues, they start by trying to find you. If the government fines you, it fines the number.

Every step is a filing, and every filing is public. No one in government is assigned to read them all.

The inversion

The DOT number was supposed to make a trucking company findable. In a chameleon network, it does the opposite: it gives the government something to fine, revoke, and put out of service, while leaving the people behind it free to start again under a new one. The disclosure law says the applicant has to tell the agency who else it’s connected to. The registration rule that carried the question has been suspended for existing carriers since 2017. The rule that lets FMCSA consolidate records and shut down a “new identity” has been on the books since 2012, and this year’s biggest chameleon shutdowns came after a crash put a network on the evening news.

What would close it

None of this needs a new law. FMCSA can put the affiliation question back on every application and every MCS-150 update: every name each officer has used, every DOT number they’ve controlled in 10 years, every company that finances or insures the fleet, under penalty of perjury. Motus already checks an applicant’s identity against a government ID and a facial scan; it can verify every listed officer the same way and refuse a registration that names no one. It can run declared power units and mileage against inspection records and flag the gaps automatically, the kind of red-flag screen Congress is now debating. It can use 386.73 before the crash instead of after it, and it can use the officer provisions of 31135 to make an unpaid penalty follow the person. States can refuse a registered agent whose death is in their own records.

Brokers and shippers can do the cheapest part themselves. Before a load is tendered, pull the carrier’s officers, prior names, address history, and declared fleet; compare them to its inspections; and write down that you did. After the Supreme Court’s 9-0 ruling in Montgomery v. Caribe Transport II in May, a jury can ask whether you did.

The four in the van

Henry Eicher was 50. Menno was 25, Paul was 19, and Simon Girod was 23. They were riding in a van on a Tuesday afternoon in Jay County, Indiana, when a truck from a network of carriers that shared officers, terminals, trucks, and a logo crossed the centerline. The carriers had different DOT numbers. The federal file had a different name for each one.

The DOT number was supposed to tell you who you were dealing with. For a chameleon, it only tells you who they used to be.

All the data available for this post is at www.teatechnologies.com, which I built and maintain and which the FMCSA uses, along with other federal and state agencies, insurers, and litigators. This site is a universal login for all our sites, including our www.motusverifi.com vetting and investigative tools. There's a 7-day trial for $1. (The $1 is to verify you. We’re constantly attacked by the people and groups we investigate.)

For most of the last two years, trucking has focused on eliminating foreign drivers who can’t speak English proficiently. Yet, the very foreign actors that hire those foreign drivers are finding ways to sidestep that accountability and enforcement process. That typically involves large donations to the political powers of both parties. What’s stopping common-sense reforms in the trucking industry that would promote highway safety?

We should start by saying I’m a Conservative. I voted for this administration. I appreciate General Flynn's service. I support our administration. After this deep dive, I question how much our Administration and General Flynn have been advised on the inner workings of the trucking industry, the fraud occurring within it, and who they’re sitting at the table with.

Dalilah’s Law cleared the House Transportation and Infrastructure Committee 35-26 on March 18, 2026. It has waited 201 days for a floor vote. In that time, the Owner-Operator Independent Drivers Association has written to House Speaker Mike Johnson asking for one, most recently after Pennsylvania State Police Trooper Pahira was struck and killed during a roadside inspection on Interstate 81 on July 1. A bill moves to the floor when leadership decides it’s worth the time. Leadership decides that partly by listening to the people who give.

This installment is about some of those people.

A political action committee exists so that people who share an interest can pool their money and put it behind candidates in the open. The law that governs them rests on one idea: if money is going to buy a hearing, the public gets to see who paid. Contributions are itemized. Committees register. Foreign money is barred. Agents of foreign governments file with the Justice Department. The ledger is supposed to be the price of admission.

I started pulling these records because the names kept showing up in the wrong files. People whose careers I’d documented in crash records, lien indexes and federal dockets were turning up in Federal Election Commission filings, in photographs from Mar-a-Lago and in Serbian and Romanian newspapers talking about their access.

I’ve voted Republican my whole life. That matters here because the people in this story aren’t partisans. They gave to whoever held the chair, and when it looked like the chair might change, some of them gave to the other side too.

What 2026 was supposed to fix

This was the year Washington went after the labor side of the model. FMCSA’s non-domiciled CDL final rule took effect March 16, 2026, limiting those licenses to holders of H-2A, H-2B, and E-2 visas. English proficiency returned to an out-of-service violation at roadside. On Aug. 31, Transportation Secretary Sean Duffy, Homeland Security Secretary Markwayne Mullin, and the Justice Department announced Joint Task Force Crossroads of America in Detroit, along with emergency actions to pull 110 entry-level training providers from FMCSA’s registry and a nationwide audit of third-party CDL skills testers.

That work targets the driver in the seat and the school that trained him. It doesn’t reach the people who recruited him, leased him the truck, factored his invoices, wrote his insurance, and dispatched him. Those people have a different problem, and they’ve been working on a different solution.

Most political giving in trucking is ordinary. The American Trucking Associations runs Truck PAC. OOIDA runs its own. FedEx, UPS, Werner, Old Dominion, Schneider and ArcBest run registered corporate committees. Carriers, drivers and suppliers have every right to organize and give, and immigrant owners have every right to organize by community. Serbian and Romanian immigrants built real companies in this industry. Plenty started in the seat, bought one truck and did it right. That story is real and common.

The problem is at the margins, where the donor list and the out-of-service list start to share names.

The Romanian branch

Federal Election Commission contribution records list Dragos Sprinceana as president and CEO of Goldcoast Logistics Group, the trade name of DMG Consulting & Development Inc., USDOT 2190975. FMCSA’s live system shows that the carrier has been out of service since Aug. 27, 2023. FMCSA’s enforcement case records show two settled cases against it totaling $889,630, and the public record doesn’t show the money collected. Day 1 of this series walked through that record and corrected parts of my own.

FEC itemized receipts for Sprinceana and his wife, Gabriela, who is listed in FEC filings as Goldcoast’s safety manager, show contributions to the Republican National Committee, to then-Rep. Matt Gaetz and to Warrior Diplomat PAC, the leadership committee of then-Rep. Michael Waltz, from 2020 through 2024. The Waltz PAC checks include $3,400 on April 21, 2023, and $3,300 on May 6, 2024, both after the first FMCSA case closed with a $791,640 settlement. One Democrat was on the list: Andy Thomson, $1,000, on Nov. 3, 2022.

In April 2025, Romania’s then-prime minister, Marcel Ciolacu, said he had asked Sprinceana to explain Romania’s situation to the Trump administration, and said it wasn’t an official envoy role, according to Romanian national press. On April 3, 2025, Sprinceana hosted a gala at Mar-a-Lago that he told the newspaper Gândul had about 700 guests, with then-Homeland Security Secretary Kristi Noem at his table. Ciolacu’s government later distanced itself from his public statements.

Sprinceana’s vehicle for that work wasn’t an FEC committee. Florida’s corporate registry lists United Strategies of America Inc., a not-for-profit he incorporated June 13, 2022, at a Wellington mailbox address he later assigned to DMG. On May 16, 2025, an amended annual report removed his name. A search of the Justice Department’s Foreign Agents Registration Act database by name shows no registration for him, for United Strategies, or for DMG. Whether any of his activity required one is a legal question this piece doesn’t answer.

The Serbian branch

Super Ego Holding LLC, Aleksandar Mimic’s leasing company, gave $200,000 to Advancing Arizona Forward on Nov. 8, 2021, and $100,000 on Feb. 3, 2022. Advancing Arizona Forward was the super PAC backing Mark Brnovich, then Arizona’s attorney general, in his 2022 U.S. Senate race.

Others in the network followed into the same race. Antonije Keljevic, principal of AAA Freight and the TRU Funding captive lender, gave Brnovich for Senate $5,000 and $2,100 on Nov. 6, 2021; the $2,100 was refunded as over the limit. Ranko Ristic, founder of Zastava Arms USA, the exclusive U.S. importer of firearms made by Serbia’s state-owned Zastava factory, gave Advancing Arizona Forward $20,000 on June 28, 2022. Radomir Dobrasinovic was credited with a $5,504.84 in-kind contribution on June 26, 2022, for a facility rental, with the amount over the limit to be reattributed or refunded. Roy Dobrasinovic gave Brnovich $2,900 on June 30, 2022, from Naples, Florida.

Brnovich lost the primary. Trump nominated him as ambassador to Serbia in spring 2025, and the White House withdrew the nomination in October. He died Jan. 12, 2026, at 59. His spokeswoman said he died of a heart attack.

The access came in person. In early 2024, according to Deutsche Welle, Ristic and four other Serbian American businessmen attended a reception at Mar-a-Lago, where, Ristic told DW, Trump called Blagojevich a “great friend” and “close associate.” Serbian Times, as reported by Kosovo Online, described a lunch with Trump in early May 2024 that it said Blagojevich arranged, about 10 days after the checks described below. In December 2024, a second group attended a gala there. Keljevic told Serbian media that Trump knows who backed him, both the voters and the sponsors.

The committee

In February 2025, the diaspora newspaper Serbian Times profiled Filip Milivojević, a Chicago transportation executive, as a founder of a new Serbian-American Political Action Committee, which it called the first Serbian lobbying group in the United States. Milivojević told the paper that money is the price of a seat in high politics and that each founder had put up enough to sit at dinner with Trump and his incoming cabinet.

The federal record agrees with him on the money, and it shows he didn’t give alone. On April 24, 2024, five men in this circle wrote checks to the same Trump committees. FEC filings list Filip Milivojević of Miami, employer Denver Cargo Inc., giving the Republican National Committee $41,300 and $47,100, Trump’s Save America PAC $5,000, and Trump’s campaign two checks for $3,300 each, for $100,000. Goran Petkovich of Rochester Hills, Michigan, listed as CEO of Gemini Transport, wrote five checks in the same amounts that day, for another $100,000. Ristic, of Park Ridge, Illinois, gave the RNC $38,400, Save America $5,000, and the campaign two $3,300 checks, for $50,000. Zoran Beric of Arlington Heights, Illinois, employer Fiber Node Services, wrote four identical checks for another $50,000. Dan Micic of Chicago, CEO of Medical Shipment, gave $100,000 split the same way as Milivojević and Petkovich.

That’s $400,000 in one day, in round blocks of $50,000 and $100,000, from a trucking executive in Miami, a trucking CEO in Michigan, a medical shipping executive in Chicago, a gun importer and an engineer in the Chicago suburbs. The RNC’s main account capped an individual at $41,300 that cycle; amounts above that are reported to the party’s separate accounts, which have their own limits. None of it is illegal on its face. It’s what a table looks like on a ledger. In October 2024, the same donor and employer gave $3,300 to Democratic Rep. Eric Swalwell and $5,000 to Remedy PAC, a Democratic committee.

The committee’s website lists five partners, including Denver Cargo and Zastava Arms USA, provides a mailing address in Beverly, Massachusetts, and invites donations. It is registered. FEC records list the Serbian American PAC as committee C00895003, a PAC with a separate account for money that can’t go to candidates. Its reports itemize $250,000 in, $50,000 from each of five founders between Jan. 22 and Feb. 21, 2025: Beric; Ristic, reported through Zastava Arms USA as a sole proprietorship; Petkovich; Medical Shipment Operating Company of Skokie, Illinois, Micic’s company; and Denver Cargo Inc. of Davenport, Iowa. FMCSA lists Denver Cargo as USDOT 3585416, doing business as Leader Freight System, with Milivojević as its officer. A motor carrier wrote that check. Only $15,000 of the $250,000 went into the account that can be given to candidates. The PAC booked the other $235,000 as non-federal money.

The reports itemize about $41,000 going out through March 2026. Tenney’s campaign got $5,000 on May 30, 2025. Michael Bouchard, a House candidate in Michigan’s 10th District, got $7,000 on March 25, 2026. NGO Serbia Online in Chicago got $3,000 for an event sponsorship. Red Curve Solutions of Beverly, Massachusetts, got $1,000 for compliance consulting. Red Curve is a Republican compliance firm; the PAC’s registration lists its address in care of Red Curve and its treasurer as Red Curve’s Jason Young, who is also assistant treasurer of the Whatley Victory Committee. The registration names no founder, officer or member. The five businessmen who told a newspaper they founded it appear on the PAC’s reports only as donors. The biggest check went from the non-federal account to SLF PAC, the Senate Leadership Fund, the Senate Republican super PAC: $25,000 on Feb. 23, 2026. Corporate money in a super PAC is legal. The ledger shows a trucking company’s money, pooled with four other founders’, landing in a Senate super PAC.

In May 2025, Goran Petković, identified as the committee’s founder and president, gave Serbian Times the price list. He said a Mar-a-Lago cocktail reception for Rep. Byron Donalds’ Florida governor campaign cost $10,000 to attend and the donor dinner that followed cost $50,000 a head, which each member paid. At a lunch that weekend, he said, Rep. Claudia Tenney, who chairs the congressional Serbian Caucus, Serbian Foreign Minister Marko Đurić and Blagojevich joined the group. On May 12, 2025, Ristic gave the Claudia Tenney for Congress Victory Fund $25,000 and Milivojević gave it $2,500. On May 30, the PAC gave her campaign $5,000.

The foreign agent

Blagojevich is a registered foreign agent. His firm, RRB Strategies LLC, holds FARA registration No. 7562 and provides communications and public affairs work for Republika Srpska, the Serb entity inside Bosnia, whose leader, Milorad Dodik, was under U.S. sanctions when the registration was filed. The Treasury Department lifted those sanctions on Oct. 29, 2025. RRB’s filings report two payments from Srpska: $625,000 on March 31, 2025, and $700,000 on Oct. 29, 2025, the same day as the delisting. That’s $1,325,000. RRB reported paying out $330,000 of it. Ristic, or a company he manages, got $230,000. A company spelled “Resilient Patriotic LLC” got $100,000 on Aug. 12, 2025, the date RRB lists as the start of Michael T. Flynn’s work on the account. Flynn filed a FARA short form under RRB on Oct. 12, 2025, at $100,000 a month, with an end date of Oct. 1. Florida records list a Resilient Patriot LLC with Michael G. Flynn as manager; whether it’s the payee is a question I’ve put to RRB Strategies. Trump pardoned Flynn in 2020 and Blagojevich on Feb. 10, 2025. Blagojevich registered as Srpska’s agent 49 days after the pardon.

The same account that paid the PAC’s founder paid a pardoned former national security adviser. Flynn’s short form gives a business address in Lakewood Ranch, Florida, on the same street as Resilient Patriot LLC, which Florida lists with his son, Michael G. Flynn, as manager and registered agent. A report released Sept. 15, 2026, by the Democratic staff of the House Foreign Affairs Subcommittee on Europe, “Pay for Play in the Balkans,” says Flynn was paid $100,000 for one month of lobbying for Srpska. It says the Flynn side of the relationship kept going after his registration ended: his Gold Institute for International Strategy sought corporate sponsors for an economic summit in Banja Luka in May 2026, and his brother, Joseph Flynn, and attorney Jesse Binnall formed AAFS Infrastructure and Energy LLC on Nov. 24, 2025, which the Federation of Bosnia and Herzegovina had named in legislation by April 2026 as the investor in the Southern Interconnection pipeline, a project the report values at about $1.3 billion with adjacent power plants. The report also says the Justice Department paid Flynn $1.25 million in March 2026 to settle his lawsuit over his prosecution. Those are the report’s characterizations of the records it cites, and I’ve asked Flynn’s representatives to respond. The same report counts 11 firms lobbying for Srpska since January 2025, at least $8.9 million, and puts Blagojevich’s share above $700,000. His own filings show $1,325,000.

On March 18, 2026, RRB Strategies filed an amendment to its supplemental statement for the six months ending Sept. 30, 2025, saying it had found an omission while preparing its tax returns. The amendment adds one disbursement, dated April 1, 2025: $62,500 to Ranko Ristic for consulting, advising, research, in-country interpreting, media liaison, travel coordination, and event planning on the Republika Srpska account. RRB’s May 12, 2026, supplemental statement adds two more payments with the same purpose language: $75,000 on Feb. 2, 2026, and $92,500 on March 2, 2026, to Strategic American Solutions LLC. Illinois records list that company as formed Dec. 4, 2025, with a registered address in Park Ridge and Ranko Ristic as manager. Ristic, the PAC founder, gives the same Park Ridge address on his FEC filings. The FARA filings themselves carry no address, so the match rests on the Illinois and FEC records together, and I’ve put the question to RRB Strategies and Zastava Arms USA.

The FEC records show what Ristic gave around those payments. Eight days after the April 1, 2025, payment, he gave the Republican National Committee $100,000. Three weeks after the Feb. 2, 2026, payment, he gave the Whatley Victory Committee $100,000, the same day the PAC sent $25,000 to the Senate Leadership Fund. Three weeks after the March 2 payment, he gave Whatley $25,000 more. From February 2025 through June 2026, he gave $455,541.02 to federal committees, about twice what RRB paid him. Money is fungible, and nothing in the record ties a fee to a check. It’s the sequence.

Seventeen days after RRB’s March 2 payment, the network hosted the candidate. On Thursday, March 19, 2026, Michael Whatley, the former RNC chair running for Senate in North Carolina, was in Chicago raising money. Politico’s Illinois Playbook reported that Blagojevich was there with a group of self-described “Trump-ocrats” and then co-hosted a dinner party at the O’Hare Hilton with Ristic. The Whatley Victory Committee’s own report lists a $3,200 in-kind contribution for catering services that day from Rada Ristic, at Ristic’s Park Ridge address, employer Zastava Arms USA. The committee’s next batch of Chicago-area checks is dated March 23. It includes $10,000 from Antonije Keljevic of AAA Freight’s captive lender, TRU Funding; $5,000 from Vladimir Vasiljevic, at the Burr Ridge address FMCSA lists for his carrier, Maxi Trans Inc., USDOT 3164581; and $50,000 from Daniel Rezko, president of DAC Developments and the son of Tony Rezko, Blagojevich’s top fundraiser, who was convicted on federal fraud and bribery charges in 2008. Ristic’s own $25,000 followed March 25. The report doesn’t say which checks came from which event.

That filing is the only place in this story where the law’s disclosure system worked as designed. A foreign principal paid an American agent, the agent paid someone, and the payment landed in a public database, a year late, on an amendment, because a tax preparer caught it.

The associations

Roy Dobrasinovic’s side of the network organizes through trade groups. The International Trucking Association lists its address as 115 55th Street in Clarendon Hills, Illinois. Compass Holding LLC, the Clarendon Hills parent of Compass Equipment Finance, Compass Insurance Group, Compass Funding Solutions, Compass Payment Services, and Compass Arena, lists the association among its affiliated companies and names Dobrasinovic as its founder and president. ITA’s events run at Compass Arena in Willowbrook.

The Romanian Moldovan Trucking Association of North America, which calls itself ROMOTANA, launched in April 2023 with a Washington gala attended by Romania’s ambassador and Rep. Tim Walberg of Michigan. It says it has more than 2,000 member companies. Its president and founder, Marcel Șomfelean, lists his day job as national sales manager for Compass Payment Services, the Compass fuel card company. Three of the seven events on ROMOTANA’s own calendar were held at Compass Arena, and its lead member benefit is a fuel card.

The PAC side and the association side meet at the same company. Milivojević’s 2020 federal contribution records list his employer as Compass Payment Services, where he is national account manager. Șomfelean’s day job is national sales manager at the same Compass fuel card company. A trade association is legal, and so is a party. I didn’t find a PAC registered to ITA or ROMOTANA. What the record shows is structure: the Serbian carriers’ association and the Romanian carriers’ association both put members in rooms owned by the same company, run by the same man, whose lending arm appears in UCC records as a secured creditor on Gold Coast entities.

Both sides of the aisle

If this were a partisan story, it would be short. Milivojević gave to the RNC and to Swalwell in the same year. Sprinceana gave to a Florida Democrat in 2022. Blagojevich was a Democratic governor before Trump pardoned him. The money follows the chair.

That’s why the enforcement side should worry. FMCSA answers to a secretary, the secretary answers to a president, and both answer to House committees whose members attend these dinners, and to a speaker who decides which bills get floor time. None of the contributions here are illegal on their face. The FEC doesn’t record intent. The record shows a sequence: penalties settled, penalties not shown paid, checks written to the party and to members who oversee the agency, a foreign agent at the table, and no public collection action on the $889,630.

How the model buys access

Here’s the build. How else? Throw on a hat. Raise money off exploited drivers and millions you owe to victims and insurers and vendors, and then go spend it on politicians who are ignorant of how trucking works and your part in it.

You run a fleet under an authority that doesn’t pay its fines, its lessors, or its workers, and when the record catches up, the number goes out of service, and the trucks move to another one. The money you didn’t pay goes somewhere. Some goes to the next authority. Some goes to a committee with a patriotic name and a mailbox in another state. The committee buys a table at a $50,000 dinner. The table buys a photo, a first name, and a phone number. The photo goes on social media, where the next driver you recruit, the next broker you pitch, and the next inspector who pulls your truck can see who you stand next to.

The cheapest input in a chameleon operation isn’t the truck, the driver, or the insurance. It’s proximity. A carrier that owes $889,630 to FMCSA and gives to the party and the lawmakers who set FMCSA’s budget has decided which invoice to pay, and so far the market has rewarded that choice.

Where Dalilah’s Law fits

Nothing in H.R. 5688 touches campaign finance, foreign agent registration or trade associations, and it shouldn’t. That’s not what the bill is for. But the bill’s own Section 6 shows what’s missing. It lets FMCSA suspend or revoke a carrier’s registration for knowingly using an unqualified driver. It doesn’t make an unpaid penalty follow the people who controlled the carrier, and it doesn’t ask who owns a carrier at all. The donors in this story don’t hold CDLs. Nothing in Dalilah’s Law will ever check their names.

What would close it

None of this requires a new law. The FEC can ask the Serbian American PAC who decided a trucking company’s money should go to a Senate super PAC. The Justice Department’s FARA unit can ask United Strategies of America whom it represents and who pays it. FMCSA can treat a principal’s unpaid civil penalties as a fact that follows the person, not the DOT number, and publish it. Campaigns already screen donors for foreign nationality and for embarrassment. They can check a donor’s company against FMCSA’s out-of-service and unpaid-penalty lists before they cash the check. And the speaker can schedule a floor vote on Dalilah’s Law, with an amendment that asks who owns the carriers, not only who drives for them.

Brokers and shippers can do their part for free. Every name in this piece is on a public filing. Before a load is tendered, the questions are who owns the carrier, who financed the trucks, and who the owner was photographed with last month.

The table

The settled penalties on the carrier whose owner’s household gave to the people who set the agency’s budget haven’t been shown as paid. Dalilah’s Law hasn’t been voted on.

The law says the ledger is the price of admission. For the people in this story, the ledger is the admission.

In 2020, the federal government wired $2.35 billion in disaster loans to insured motor carriers, and it kept wiring as freight entered the most profitable stretch in its history. Match the SBA’s loan data against FMCSA’s insurance filings, and a pattern fell out: $79.6 million to RRG paper, 12 loans during a liquidation, and 1 carrier approved for $150,000 two days before its dead insurer’s filing lapsed.

In the spring and summer of 2020, the federal government wired $2.35 billion in COVID disaster loans to federally registered motor carriers. I matched the SBA’s own bulk loan data against FMCSA’s insurance filings, carrier by carrier, name by name, state by state. Here is what fell out.

The Economic Injury Disaster Loan program was designed to keep genuinely injured businesses alive, and in March, April, and May of 2020, many passenger businesses were. Motorcoach and limousine operators, who show up all over this data with the largest loans, watched their entire industry stop existing in a week. A charter bus company taking $500,000 in April 2020 is not a scandal. It’s the program doing what Congress built it to do. No one was traveling, and passenger carriers were dying in mass-casualty financial events.

Meanwhile, the freight market was printing money. By June 2020, spot rates were fine, and by the fall the industry was entering the most profitable stretch small trucking had ever seen. Rates went vertical and stayed there for eighteen months. The loans kept flowing.

My investigation matched 27,923 insured motor carriers to SBA EIDL disbursements totaling $2.35 billion. The method used exact legal-name matches, confirmed against the carrier’s physical state, and limited to insured entities. The true number is higher. This is our base.

Sort that money by the type of insurance paper the recipients ran on, because in trucking, the paper tells you which carrier the recipient is. It also tells you whether the carrier is open.

$79.6 million to the shadow market

Regular readers know the argument from my earlier reporting: risk retention groups are single-state-chartered insurers that write trucking liability nationwide under a 1986 federal preemption, hold whatever capital their domicile tolerates, and federal statute bars them from every state guaranty fund in America. When one fails, and they fail, the crash victims get nothing. I documented 76 of them, insuring roughly 29,000 carriers earlier this year.

Cross that shadow market against the COVID loan data, and you get this: 1,086 carriers running on RRG paper collected $79.6 million in EIDL money.

Some of that is defensible. The biggest single book belongs to one RRG run by a national association comprising 235 carriers, $12.3 million. Owner-operators were exactly the businesses the early-2020 market genuinely hurt, and this RRG is the oldest and most legitimate operation in the category. While they may be the oldest and most legitimate, not all are. Two points to make here. 1. That association’s leadership has testified to legislative committees at least 6 times, demanding no increase in federal insurance minimums. 2. Their COO sits on the NRRA Board of Directors as Secretary. When testimony arrives on Capitol Hill, check a layer or two beyond the surface, and you usually find a reason or two guiding it. NRRA openly credits this association with killing the minimum insurance increase. Their own marketing material says that when federal policymakers proposed raising the minimum liability requirement to $4.5 million per truck, said association “led the charge in Washington, D.C.” and successfully blocked the change, holding the association up as a template of RRG success.

Hold two major Association positions side by side and see who stands under both. Position one: the insurance minimum must stay at $750,000, a figure set in 1980, because raising it would crush small carriers. Position two: aggressively enforce English proficiency, which said association championed and, in June 2025, became an out-of-service offense. Now run the data. Carriers insured by risk retention groups draw English proficiency citations at a rate 38% higher per inspection than the rest of the entire US trucking fleet. Your foreign-driven fleets comprise non-English-proficient RRG-insured fleets. The same carriers, in other words. The RRG sector’s client base is the population that the low minimum protects and the population that the ELP campaign removes from the road. Fight to keep their insurance cheap, fight to take their drivers out of service, and the two positions only look contradictory until you notice what they share: in both, the carrier keeps buying the policy right up until the roadside inspection ends the trip. The premium clears either way. Whatever else it is, it is not the voice of the small trucker. It is the voice of the paper.

While the association demands a static, aged insurance minimum and demands the same insureds be removed for ELP and non-domiciled enforcement, they are, as far as anyone knows, a legitimate RRG; not all of them are. What follows is different.

Universal Casualty Risk Retention Group, an insurer whose book I have reported on at length in connection with a multistate carrier network now in federal litigation, shows 108 carriers matched to $11.05 million in disaster loans. Then there is County Hall.

The Spirit lineage collects federal money

If you read my RRG article a few months back, you know the chain. Federal Motor Carriers Risk Retention Group was liquidated in 2011. The man regulators identified as controlling it through its program manager then stood up Spirit Commercial Auto RRG in Nevada in 2012. Spirit collapsed in 2019 with roughly $199 million in unpaid losses against $42 million in assets, a forensic audit that found at least $30 million missing, and a state complaint calling the whole arrangement a vast fraudulent enterprise. Those are the Nevada Insurance Commissioner’s allegations, and the case is still in litigation. While Spirit was still writing, a third RRG appeared in North Carolina with ties to the same network: County Hall.

County Hall’s insured carriers collected $6.57 million in EIDL loans across 78 matched carriers.

A lineage of three risk retention groups, two of them liquidated, the third formed while the second was being looted according to state regulators, and the surviving vehicle’s book of trucking clients was drawing federal disaster money through the same season the receivers were still counting what was missing from the last one. No system flagged any of it. The SBA saw an insured motor carrier. FMCSA saw a filing. Nobody saw the pattern. SBA and FMCSA didn’t connect until I merged them; neither did Interpol RED or other watchlists.

One name on the dead-book Spirit casualty list connects this story to another. MGR Freight System, a carrier I have reported on in connection with the Super Ego network, sits near the top of Spirit Commercial Auto RRG’s book by fatal crashes: six fatal wrecks and 160 total in the record, insured by an RRG that collapsed, owing $199 million it did not have. When Spirit died, MGR did not leave the shadow market. It moved to MS Transverse Specialty and kept running.

Twelve loans during a liquidation

Vermont regulators seized Global Hawk Risk Retention Group in the spring of 2020. Its filings claimed $42.7 million in assets; the banks held $609,489. The court’s liquidation order, entered June 8, 2020, said the 1,008 trucks it covered were effectively uninsured. Its president, Jasbir Thandi, later pleaded guilty to federal fraud charges for wiring the money away.

In the data, twelve EIDL disbursements totaling $649,200 went to carriers whose insurance filing of record was Global Hawk. All twelve were approved between June 5 and September 4, 2020. During and after the liquidation.

A carrier called Impossible Express Lanes LLC shows a Global Hawk policy effective March 17, 2020, riding that paper straight through the collapse. On September 4, 2020, the SBA approved it for $150,000. Its Global Hawk filing lapsed two days later. Federal disaster money, approved to a carrier insured by a corpse, two days before the paperwork showed it.

At scale, across their lifetimes, just those three dead RRGs, Federal Motor Carriers, Spirit, and Global Hawk, wrote paper for 21,035 different motor carriers in the federal filing data. That is the universe of policies insurers sold without a guaranty fund that no longer exist. Every claim in that universe that matured after the collapse was included in the liquidation estate rather than paid.

The carriers those dead insurers wrote paper for, 19,588 of them across Federal Motor Carriers, Spirit, and Global Hawk, ran up 49,812 crashes in the record, 1,479 of them fatal, 1,972 people dead, 23,519 injured. Every one of those policies was sold with no guaranty fund behind it. Sixty of those carriers managed to be insured by all three companies in turn, riding one collapsing RRG into the next, and at no point did the system that let them buy the first policy stop them from buying the third.

The suite in Sheridan, Wyoming

One more thing the data coughed up, which tells you how thin the whole verification layer is.

A suite at 30 N Gould Street in Sheridan, Wyoming. It is a registered agent’s address, a legal mail drop; using one is lawful. At that address, FMCSA data show 95 registered motor carriers on file. The SBA’s loan data show 115 EIDL recipients at the same address, totaling more than $5.1 million to one mailbox, and most of the recipients are not trucking companies. They are e-commerce shells, crypto consultancies, supplement brands, an outfit called American Pillowcase, suite numbers stacked on suite numbers, none of them with a truck.

Two federal systems, FMCSA registration and SBA disaster lending, both accepted the same empty suite in Wyoming as a place where businesses exist. The carriers and the pillowcase company passed through the same door because the door checks nothing. That is not a trucking scandal or a Wyoming scandal. It is what the entire federal verification layer looks like when you find the single address where it all piles up.

Same filing cabinet, equally blind

The pattern across everything above is not sophisticated fraud. It is the absence of a requirement to check.

The SBA’s automated system accepted a DOT number, an MC number, and an insurance certificate as proof of a real transportation business, and never asked whether the insurer behind the certificate was solvent, or seized, or the third company in a documented insolvency chain. FMCSA accepts the insurance filing as proof of financial responsibility and never asks who filed it; in its records today, a filing from a twice-failed operator’s successor RRG counts the same as a filing from a century-old admitted carrier. FMCSA numbers show 34% of actively insured carriers, 71,953 of them, sitting on paper classification flags as non-underwritten, and the carriers on RRG paper run a 16% higher crash count per carrier than everyone else, on books that skew toward small fleets that should crash less.

Congress is currently being told the data doesn’t exist to evaluate whether motor carrier insurance requirements are adequate. The data exists. It’s public. Matching takes a database and the willingness to look. What does not exist, anywhere in the federal government, is a single place where the insurance filing, the loan record, the crash file, and the corporate registration are read together. Until that desk exists, the worst carriers will keep running on the worst paper, and when the government hands out easy money, that paper will be first in line.

EIDL records from the SBA’s public DATA Act bulk release (2.77 million rows) matched against FMCSA Licensing and Insurance filings and the FMCSA carrier census (2.2 million carriers) in the TEA Intel database. Matching used an exact legal-name comparison after standard suffix normalization, confirmed against the carrier’s physical state of record; the method undercounts by design, so all totals are floor values. Insurer classification follows the insurer taxonomy; we verified RRG identification against the platform’s RRG profile set. Loan presence does not indicate wrongdoing by any individual recipient; the SBA makes eligibility determinations. Full match table available on request.

After I published “Why I went to war with the worst of trucking,” a reader named Chris left a comment asking whether I could give ordinary drivers some tips on protecting themselves from bad truck drivers, and whether there are indicators people can watch for on the highway.

There are. Most of the time, the truck tells you. That matters, because you are the one most likely to pay if it goes wrong. In 2024, 5,340 people died in crashes involving large trucks, according to the National Highway Traffic Safety Administration, and 70% of them were in the other vehicle. When a car and an 80,000-pound truck meet, physics picks the loser before anybody’s insurance does.

The single most useful thing I can teach a driver is this: a truck’s condition is a story about the people behind it. The equipment tells you about the ownership, the management, and the driver who decided that rig was good enough to put on the road. More than that, it tells you whether that truck is a threat.

I have made a version of this argument to Collin Mooney, the executive director of the Commercial Vehicle Safety Alliance, the organization behind North America’s roadside inspection standards. My push to the industry has been that a carrier does not need to survive a roadside inspection if it can prevent one.

If a truck looks right, the lights all work, the tires have tread, the driver is belted in, the truck is clean, and it holds its lane, an officer can reasonably decide his time is better spent somewhere else. If the truck is trashed, the trailer lights half work, the wheels are rusted, a tire is low or flat, the driver isn’t wearing a belt, and the truck can’t stay between the lines, that officer knows his time is well spent pulling it in. We previously worked with the VA DMV Commissioner on limiting who the State stops or pulls into scales based on historical safety performance. The best carriers were stopping up the scales and forcing the worst bad actors to bypass. It’s all the same mindset.

During the CVSA’s International Roadcheck from May 12 through 14 this year, inspectors across North America conducted 54,575 inspections and placed 10,350 vehicles out of service (about 19%), along with 3,184 drivers (about 5.8%). Brake problems were the top vehicle violation. Tires, lights, and cargo securement were right behind them. Those are the same problems you can often see from the next lane. A truck that far gone didn't get there overnight. Somebody looked at it and sent it out anyway.

You can read a truck the same way an officer does. You just need situational awareness and a little discernment. Here is what I look at.

Start with the tires and wheels, because they are the easiest to see and the hardest to fake. Look for tread you can’t see from the next lane, sidewalls with bulges or cords showing, a tire that sits visibly lower than its neighbors, and rust streaks running from the lug nuts, which can mean loose or broken wheel fasteners. Does it even have all its lug nuts and studs? A tire that lets go at highway speed throws rubber and steel belts into traffic. A wheel that comes off is a 100-pound projectile.

Then look at the lights. At night or in rain, a trailer with half its marker lights dead, a missing brake light, or no working turn signal is not just a ticket. It means the driver either never walked around the truck before leaving or saw the problem and drove anyway. Neither is someone you want behind you.

Watch the lane. A truck that wanders inside its lane, rides the line, corrects late, or drifts onto the rumble strip is telling you something about the person driving it. Fatigue and distraction both look like that. In my “Last Eight Seconds” piece, I wrote about a driver I watched nodding off for an entire shift on his own cab camera before he killed a young woman at a red light. The weaving came first. If you see it, don't stay beside that truck or pull in front of it. Back off and let it get well ahead of you.

Rate the strap work. Look at the cargo. Flatbed loads should be strapped or chained, and the straps should be tight, not flapping. Cover loose material like gravel, sand, mulch, or trash where state law requires it. Federal cargo securement rules sit in 49 CFR Part 393, Subpart I, and cargo securement made the CVSA’s list of top vehicle violations this year. If you see a load that is shifting, leaking, unstrapped, or uncovered, move away. The last thing you want is a rock or a piece of somebody’s load coming through your windshield.

Look for mud flaps, sometimes called splash guards. Most states require them, and for good reason. A truck without them throws road debris, gravel, and water spray straight back at the car following it. Missing flaps also tell you a lot about a fleet that doesn’t sweat the details.

Look at the door. Interstate trucks have to display the carrier’s name and USDOT number. A legitimate fleet paints or applies it cleanly. A DOT number that is taped on, hand-lettered, half peeled, or missing altogether can be a sign of a carrier swapping identities, which is exactly what the CBS 60 Minutes investigation into chameleon carriers documented this spring. Be fair about this one. Plenty of good owner-operators and leased trucks run plain white, and a missing logo alone proves nothing. Add bald tires and a drifting lane, and the story gets clearer.

Look in the cab if you can do it safely in passing. A driver who isn’t wearing a seat belt, has a phone in his hand, or is looking down more than up is a driver whose habits extend well beyond the belt and the phone. You can usually see the belt across the chest from the next lane.

The whole truck tells a story, too. A dirty truck is not necessarily a dangerous one, because trucks get dirty doing honest work. But a rig with rust bleeding through the frame, body damage nobody fixed, mismatched equipment held together with ratchet straps, and a cab that looks like a storage unit tells you how the people above that driver think about maintenance and money.

Reading a truck is half of it. The other half is driving in a way that keeps you out of its path.

Stay out of the left lane except to pass. Lingering there forces trucks and faster traffic to pass you on the right, which is where crashes start. Do not pass a truck on the right if you can avoid it. The right side of a tractor-trailer is its largest blind spot, and a driver changing lanes to the right often cannot see you at all. The Federal Motor Carrier Safety Administration's rule is simple: if you can’t see the driver’s face in his side mirror, he can’t see you.

Don't tailgate a truck, and don't cut in front of one and hit your brakes. A loaded tractor-trailer needs far more distance to stop than your car does. When you slide into the gap in front of it, you take away the space that driver was counting on. Give a truck room ahead and behind, and do not ride next to it longer than you have to. Pass it decisively or drop back.

Learn to drive for the other people around you, not just for yourself. Defensive driving is anticipating what the worst driver near you is about to do and making sure you are not where it lands. That is what I teach professional drivers, and it works just as well in a minivan.

If you want a record of a truck that worries you, capture it safely. I use camera glasses for this: one glance, one press, and I have the image or the plate without taking my hands off the wheel. A dashcam does the same job. Better still, hand the job to a passenger. Do not pick up your phone to take a picture while you are driving. You will become the hazard you were trying to document, and it is illegal in many states.

Once you have the DOT number, look it up later. The FMCSA’s SAFER Company Snapshot at safer.fmcsa.dot.gov is free and shows a carrier’s authority status, fleet size, inspection results, out-of-service rates, and reported crashes. A carrier with out-of-service rates far above the national averages listed on that page shows a pattern. If a truck is an immediate danger, call 911. Many states also run a highway patrol line for non-emergency reports, posted on signs along the interstate. If you want to file a complaint about a trucking company, FMCSA runs the National Consumer Complaint Database for exactly that.

None of this means you should treat every truck as a threat. Most trucks on the road are driven by professionals who do this job right every day, and they watch the bad ones as closely as you do. The point is discernment. The best carriers in this country maintain their equipment, train their drivers, and put trucks on the road that look like somebody cares about them, because somebody does. The worst ones can’t hide it as well as they think.

The truck is telling you a story. Read it, and if you don’t like how it ends, don’t be in the next chapter.

A father was on the phone with his daughter when the truck hit and killed her. That case came in last week, and it will never close for him.

A father was on the phone with his daughter when the truck hit her. He heard it happen. Then he heard nothing, and he stayed on the line anyway, because there was nothing else on God’s earth he could do from where he was standing. That call is the last conversation he will ever have with her. It will play in his head at red lights, in the shower, and every time his phone rings for the rest of his life.

He would go on to call 911 and wait for a Trooper to call him back about the condition of his child. His daughter. The call came, and he found out that listening to his little girl die because of a careless carrier and bad driver was the last call he would ever have with his daughter.

That case landed on my desk last week. It’s one of hundreds I work on around the country, trying to make carriers and drivers “right,” or to make victims whole. It will settle or go to trial, and either way the file will close. It will never close for him. None of these cases do. The families who bury someone carry it forever, and the ones who live through the crash carry it in their bodies. I have sat across from people who came out of a truck crash without legs, without eyes, missing a hand or an arm, with a face strangers stare at in the grocery store. The lawyers call that damages. The people living it call it Tuesday.

I get asked a lot of questions about why I do what I do. Some come politely, from drivers and safety directors. Some come in comment sections. Some come through lawyers. What’s his angle? Who’s paying him? Is he a defense guy or a plaintiff guy? Why does he keep writing about C.H. Robinson or Super Ego? Those are fair questions, and I would rather answer them myself than let somebody else answer them for me. So here it is.

When I get these cases, and I get to crash scenes, or I watch the videos, I reimagine what happened here and what that felt like for the daughter and the father. The hopelessness. The waiting. The hoping and the praying. Then I replay the event, and I watch how the slightest lane change two minutes ago became the last decision a victim made to put themselves unknowingly in the path of a dangerous carrier or driver who in no way grasps the totality of his moral, ethical, or professional responsibilities to the people he shares the road with.

Start with the part that has nothing to do with trucking. My father died in a motorcycle crash. He shot himself decades earlier when we were small children. I have lost siblings to drug overdoses before 30 and 40 years old. Both of my parents were addicts; I was raised from age 4 by my dad’s mother on a farm, and I was emancipated at 15. I am not telling you that for sympathy. I am telling you because I know exactly what the family on the other end of my case file is about to go through, usually before they do. There is nothing like holding the cold, dead hand of somebody you love because someone else made a bad decision and never wrapped his mind around his moral, ethical, and professional responsibility to share the road safely. I have held that hand. I would not wish it on the people I investigate.

In August I wrote about the last eight seconds of Ashley Chapman’s life. She was stopped at a red light on Route 17 in Gloucester, Virginia, when a loaded trash truck driven by a man who had been nodding off all day ran into the back of her Chevrolet and drove it into the gooseneck flatbed stopped ahead of her. I watched his whole day on the forward-facing and driver-facing cameras. The camera system in his cab did not issue a forward collision warning until he was about a foot from her bumper. A mile earlier, she and a pickup driver had swapped lanes, the most ordinary thing two drivers ever do, and that swap put her in front of him instead of the other guy.

The point of that piece was not the last eight seconds. It was everything stacked underneath them. A short-haul exception that meant no electronic log ever recorded how hard he was running. Pay by the load against landfill gates open eight or nine hours a day. A carrier whose address of record steered its federal review to an office full of accountants instead of the yard full of trucks. A customer that kept renewing the contract while the public record got worse. Someone made every one of those decisions to optimize revenue, and each looked survivable on its own, because most days it was. On her day they lined up.

That is the whole thesis of my work, and it answers the question of motive. The more cases I work, the more footage I watch and the more scenes I stand on, the more certain I am that almost none of these crashes are unpredictable. They show up looking like lightning strikes. They are almost always the compound interest on years of decisions made revenue first, with the moral and professional obligations somewhere in the back of the line. The last eight seconds get decided in rate confirmations, contract renewals, and audit samples, months and years before anybody bleeds.

Which brings me to the freight market, and to why the brokerage side of this industry keeps showing up in my reporting. Here is the pattern. The worst brokers choose the worst carriers to haul the cheapest freight at the lowest rates. That is not a slogan. It is basic trucking and broker math. A load priced below what it costs a legitimate carrier to run will still move because somebody out there doesn't carry the costs a legitimate carrier carries. No safety director. No real drug and alcohol program. No maintenance schedule worth the paper. Insurance bought on a self-declaration. Drivers paid in pennies, or not at all. A carrier with no compliance program has no compliance overhead to absorb, so it can haul for nothing and still make money, and the legitimate fleet down the road is bidding against a ghost.

The carriers suing C.H. Robinson and Total Quality Logistics put numbers on that this fall. Stevens Trucking and five other asset-based carriers filed a racketeering and false advertising complaint Sept. 23 in the Eastern District of Texas, Marshall Division, case No. 2:26-cv-00869. The complaint cites American Transportation Research Institute data putting the marginal cost of running a truck in 2022 and 2023 at about $2.26 a mile, with roughly 42% of that going to labor. That leaves about $1.31 a mile in costs every carrier pays whether its drivers get paid or not. The plaintiffs allege team loads went out for less than $1.50 a mile. Do the subtraction, and about 19 cents a mile is left to pay two drivers. Those are allegations; both brokers deny them, and C.H. Robinson has said it rejects the lawsuit’s characterization of the company and its practices. The math does not care who wins the motion to dismiss.

Strip away the fraud, and the worst carriers in this industry fail on three things: identity, disclosure, and accountability. Those are the foundations of any civilized system, not just trucking. You know who you are dealing with. They tell you the truth about what they are. They answer for what they do. A chameleon carrier breaks all three by design. It hides who owns it. It does not disclose its association with the last company that ran the same trucks, drivers, and dispatchers under a different DOT number. When the crash comes, it skirts accountability by dissolving into the next entity. The scheme is not a bug in the paperwork. It is the business model. In one case, Gold Coast stooped so low as to move the company into the name of a driver who died driving for the company five years earlier.

We built a system that lets them do it, because nearly every gate in civilian surface transportation runs on the honor system. Electronic logging devices are self-certified by the companies that sell them. Entry-level driver training providers put themselves on a federal registry by attesting that they meet the standard. A carrier declares its own fleet size on its registration, and I have read insurance files where an operation declared one truck to an underwriter while the network it belonged to was moving hundreds of VINs. The CBS 60 Minutes segment I worked on reported about 350 federal investigators overseeing roughly 700,000 registered trucking companies. Self-declaration plus a skeleton enforcement staff is not oversight. It is an invitation.

Super Ego is the clearest example I know. On Sept. 17, 2025, C.H. Robinson announced its Carrier of the Year winners, and the award in the 1,000-plus truck category went to Super Ego. Seven months later, on April 12, 60 Minutes aired an eight-month investigation into the network, citing Department of Transportation data showing Super Ego-connected carriers logged nearly 15,000 safety violations and 500 crashes over two years. Super Ego called the report misleading and said it is an equipment leasing company, not a carrier. I have read the public court records on the insurers that rescinded their policies one after another. Readers can decide which description fits.

Here is where my issues with C.H. Robinson come from. When I started publishing what the federal roadside inspection records showed about the carriers moving on Robinson loads, what came back was not a better vetting program. It was complaints about me. A data vendor whose platform I was using cut off my access after Robinson complained, and the company complained to the media side of a major trade show that I had recorded its people. I did not stop. The roadside records are public. The Carrier of the Year press release is public. The $604 million advisory verdict a Dallas County jury returned against the company on July 23 in a fatal crash case is public, and the company has said it will challenge it. None of that is a vendetta. It is the record, and my job is to read it.

I want to be fair to the brokerage side, because I spent years there. Most brokers are not the problem. Plenty of them vet hard, turn down cheap capacity, and lose freight as a result. The Supreme Court made their homework matter on May 14, when it ruled unanimously in Montgomery v. Caribe Transport II that federal law does not shield brokers from negligent selection claims. That ruling did not create a duty to care who hauls your freight. It confirmed that the duty was always there.

Now the question I get most: do you take plaintiff work or defense work? For most of its history, TruckSafe has taken only defense expert work. I honored that unwritten rule to support the industry. Over the years, I personally decided to start taking select plaintiff cases. I did not make that decision lightly, and I did not make it for money. I made it because our market and our industry are being destroyed by the worst actors possible, and highlighting the problem is not the same as fighting it. I spent time building tools to trace carrier networks for investigations and enforcement. I don't believe you can build a system like that and then refuse to use what it shows you to help make victims whole or make the industry right again. We have systems and executives in the market who just want to make money on the enforcement and investigative side; I am not one of them. I will not hide who or what a broker or carrier is or has been simply for dollars at the expense of not making the victim whole. That is the point of all of this.

My standard does not change based on who signs the engagement letter. If a broker did its homework, I will say so, and I have. We are defending a broker as we speak who had a .01% driver OOS rate yet has been ambushed as a “bad carrier selection.” If a carrier ran a real safety program and a driver made a mistake no program could have prevented, I will say that too. If the record shows a company priced its freight so low that only a ghost could haul it, picked the ghost, and then acted surprised at the funeral, I will say that, and I do not care whose side it helps. I choose my clients carefully. I do not care what you pay me. If you are not a principled operator, I do not want your business.

That goes for the media side too. My content reaches about 250 million views a year, and offers come in constantly: push this product, endorse this vendor, carry this agenda. I push maybe four, and I do most of those for free, because they are real advocacy groups, associations, and programs that actually help drivers and the people they share the road with. Influencers in this industry will take money from anyone who asks, every single day, simply because someone is willing to pay. I am not that guy. I make my own money. I do not need yours. I was never designed to be an influencer; I am a man focused on my work, and that work is to root out the worst of our industry and make victims whole wherever that leads.

The truth is, a lot of my work isn't billed at all. I consult for free most of the time. Partners have to push me to bill, and some of the case reviews I do are labeled for exactly what they are: uncompensated reviews provided as a resource, not retained opinions. The standard creed in the consulting and legal world is that if you thought about a case in the shower, you bill for the shower. I have never been able to wrap my head around that as work. Thinking about how a family ended up in my file is not a line item. It is the job.

None of this means I have written off the bad actors. The majority of our business is helping the worst fleets in this industry become the best ones, whether you are a trucking company, a broker, or a vendor. I believe in redemption, and I believe the intelligence that exposes a bad operation is the same intelligence that can fix one. We will not make our highways safer without reaching across the aisle and working with the operators who need it most. I will sit down with anyone who wants to get better at what they do. But if we get into a relationship and it becomes clear you are not trying to be above board, that you want the badge without the work, we are done. We do not hitch our wagon to sorry carriers and sorry brokers who will not change.

I believe the people running this country’s transportation agencies are serious about enforcement right now. Enforcement alone will not fix it. Washington cannot audit its way out of a system where 350 investigators chase 700,000 companies that grade their own paper. The industry has to fix it: shippers who ask who actually hauled their freight, brokers who refuse capacity that cannot exist at that price, insurers who verify what they underwrite, and carriers who stop treating compliance as a cost to be competed away.

Everybody in this industry should want it turned right side up again, because everybody in it is paying for the bottom of it. The legitimate carrier pays when it loses the lane to a rate only a ghost can haul. The legitimate driver pays in a paycheck squeezed to match the operator who doesn’t pay his drivers at all. Every fleet pays at renewal, when insurers price in the verdicts the worst operators earned. Brokers and shippers pay when a crash puts their name in the caption. The motoring public pays in the only currency that can’t be refunded. The bad actors don’t just cut corners. They take the cost of every corner they cut and hand it to the people who didn’t cut any.

For a lot of brokers, carrier selection has always been graded at the floor. Does the carrier have a DOT number, operating authority, and an insurance certificate on file? If yes, tender the load. To me, that is the same as hiring a driver off his CDL instead of a road test. The regulations let a carrier accept a CDL in lieu of the road test under 49 CFR 391.33. You have no idea who the examiner was, what the licensing agency checked, or whether the license came out of a mill. Yet you trust it as the declaration that this driver is safe, and you put him on the road. Ten more minutes in the passenger seat would tell you who he is, how he drives, and whether you want him behind the wheel of your truck.

Brokers don’t get a ride-along. What they get is better: years of public history on every carrier they tender to. Inspection records, out-of-service rates, crash history, authority changes, shared addresses, shared phone numbers, shared equipment, and insurance that keeps getting canceled. The data that tells you a carrier is high risk or below board is endless, and most of it is free. Stop grading carrier selection at the floor. Look at the risk profile you are adopting every time you source the cheapest truck on the board.

We don’t need a new regulation to tell us a carrier is bad. We need brokers to put common sense selection protocols in place that confirm what we already know in our gut from the carrier’s own history. The record is sitting there. Read it before you tender, not after the funeral. Make the selection with a moral, ethical, and professional standard mindset, not a financial one. Ask yourself: would I want my daughter, son, or spouse next to this truck on the highway?

Until that happens, I will keep reading the records, and I will keep taking the cases worth taking, on whichever side of the courtroom the truth happens to sit. I owe that to the legitimate carriers and drivers of this industry who play by the rules and lose loads for it. I owe it to Ashley Chapman’s family. I owe it to the father who stayed on the line.

He will hear that call for the rest of his life. I want the people who priced that load to hear it too.

On May 11, 2019, Volodymyr Zhukovskyy failed a field sobriety test in a Walmart parking lot in East Windsor, Connecticut, and refused a urine test. Connecticut suspended his privilege to drive in that state and sent the notice to the Massachusetts Registry of Motor Vehicles, the agency that issued his commercial driver’s license. That notice should have ended his commercial driving. Instead, it went into a backlog of unprocessed out-of-state violation reports, and his CDL stayed clean on paper.

Forty-one days later, at about 6:30 p.m. on June 21, 2019, the 2016 Dodge pickup he was driving for Westfield Transport, towing a flatbed car hauler, crossed the center line on U.S. Route 2 in Randolph, New Hampshire, and went through a formation of riders from the Jarheads Motorcycle Club, Marine veterans and their spouses headed to a charity event at the American Legion post in Gorham. Seven died: Albert “Woody” Mazza Jr., 59, the club’s president; Edward “Taz” Corr, 58, and his wife, Jo-Ann Corr, 58, of Lakeville, Massachusetts, weeks from their 38th anniversary; Michael “Fritz” Ferazzi, 62, of Contoocook, New Hampshire; Daniel “Danny Boy” Pereira, 58, of Riverside, Rhode Island; Aaron “Stitches” Perry, 45, of Farmington, New Hampshire; and Desma Oickle, 42, of Concord, New Hampshire. Prosecutors said Zhukovskyy had taken heroin, fentanyl, and cocaine that day, swerved repeatedly before the collision, and told police he caused it.

This is the run of cases behind my argument that Congress needs to pass Dalilah’s Law. I’ll start with the concession, because this one needs it. Zhukovskyy came to the United States from Ukraine at 10 and held lawful permanent resident status. He spoke English. The parts of the bill that get the airtime- English proficiency and the limits on who can hold a CDL- wouldn’t have touched him. The part that would have is the least glamorous section in the bill. And the company that put him in that truck sits in a gap that Dalilah’s Law doesn’t close at all.

Where the case stands today

Here’s the update, as of Oct. 3, 2026.

New Hampshire kept Zhukovskyy off its roads for the longest term its law allows, and that term is over. After the crash, the state suspended his driving privileges. He asked for them back. In May 2024, Administrative Law Judge Ryan McFarland of the Department of Safety found he had driven in an unlawful or reckless manner that contributed to the crash. On July 10, 2024, McFarland set the suspension at the seven-year maximum but dated it from June 24, 2019, three days after the crash. The state had asked for the seven years to start in 2024, which would have run to 2031. McFarland credited Zhukovskyy’s testimony that he had been sober for five years. Zhukovskyy appealed, and in May 2025 Merrimack County Superior Court Judge Martin Honigberg upheld the finding, writing that the hearings examiner reasonably called his decision to keep driving “a gross deviation” from what a reasonable person would do. The suspension expired June 24, 2026.

I found no public report that Zhukovskyy has applied for a license in New Hampshire or anywhere else since it expired. His Massachusetts license status isn’t public. When the Boston Globe asked in 2024, the RMV cited state privacy law.

The Connecticut case that should have stopped him in 2019 finally closed in 2025. On April 14, 2025, he entered an Alford plea in Hartford Superior Court to operating under the influence for the East Windsor arrest, meaning he didn’t admit guilt but conceded the state had enough to convict. He got 18 months of probation, 100 hours of community service, and random drug testing. That probation runs into the fall of 2026. It is the only criminal conviction he has from 2019, and it came almost six years after the arrest.

His immigration case hasn’t moved. Immigration and Customs Enforcement took him into custody on Aug. 10, 2022, the day after a Coos County jury acquitted him. An immigration judge ordered him removed on Feb. 3, 2023, and his lawyers sought asylum. ICE had paused repatriation flights to Ukraine in March 2022 after Russia invaded, and he was released under an order of supervision in April 2023. I found no public record that the removal order has been carried out.

Coos County Superior Court Judge Peter Bornstein dismissed eight impairment-related charges before the case reached the jury, ruling the state hadn’t proved he was impaired at the moment of impact. The defense put the blame on Mazza, whose blood alcohol content was .135, and argued the collision happened on the double yellow line. On Aug. 9, 2022, after less than three hours of deliberation, the jury acquitted Zhukovskyy of seven counts of manslaughter, seven counts of negligent homicide and one count of reckless conduct. Gov. Chris Sununu said the seven bikers did not receive justice. Attorney General John Formella said he believed the state proved its case.

The company

Westfield Transport hired Zhukovskyy on June 18, 2019. The crash happened on his first trip, three days later. Federal rules give a motor carrier 30 days after hire to pull a new driver’s motor vehicle record and employment history under 49 CFR 391.23. Westfield didn’t need the 30 days. The National Transportation Safety Board found it ran no background check.

The owners didn’t need one either. Dunyadar “Damien” Gasanov told federal investigators he met Zhukovskyy the day he hired him. Prosecutors later established he had known him for years and knew about his drunken driving charge. What a background check would have shown, according to the employer records the NTSB collected: a 2013 Massachusetts drunken driving arrest that cost him his license until December 2016; a 2014 Ohio guilty plea to driving on that suspended license and handing an officer someone else’s ID; a 2017 drug possession conviction; a December 2018 firing from Universe Express over suspected drug use; a Feb. 11, 2019, drug paraphernalia arrest in Baytown, Texas; and on June 3, 2019, a rollover in Baytown in a Mack hauling cars for FBI Express, which fired him four days later for not completing a post-crash drug test in time and for the crash. Westfield hired him 11 days later.

The NTSB’s review was wild. Of 150 driver logs investigators examined, 28 were falsified. The company told drivers to disconnect their phones from their electronic logging devices so driving time wouldn’t record, and its manager showed investigators how it was done. The board found Westfield tried to add Zhukovskyy to its insurance policy about an hour after the crash. In the 18 months after the carrier graduated from FMCSA’s new entrant program, it logged 48 roadside inspections and 23 out-of-service violations, with a driver out-of-service rate of 20.8%, nearly four times the national average, and three BASICs in alert. FMCSA rated it moderate risk and never ran a compliance review. After the crash, FMCSA’s own investigators recommended an imminent hazard order. The agency declined. By August 2019, Westfield and its sister company, East Transport, told FMCSA they were out of business.

The NTSB tied at least 21 motor carriers to the Gasanovs through shared vehicles, drivers, addresses, and officers. When investigators went to Zhukovskyy’s family home in West Springfield, they found a DAKS Express sign on the mailbox, and vehicles marked Vlad’s Transport in the driveway. Zhukovskyy had dispatched for Vlad Transport, which had no USDOT number. County Transport shared three trucks with identical plates and VINs and then refused a safety audit. East2West Transport, started Aug. 22, 2019, was managed by a former Westfield driver and employed a Westfield driver with a suspended license. When I reported in January, DAKS Express and East2West still held active authority.

Dunyadar Gasanov was indicted on falsification of records, conspiracy, and a false statement. His brother Dartanyan Gasanov, the company’s listed president, treasurer, secretary and director, was indicted on one count of falsification of records, accused of logging himself off duty on three occasions between April 1 and June 20, 2019, when prosecutors say he was driving Westfield trucks. That count carries up to 20 years.

Dunyadar pled guilty in August 2024 to three counts of making false statements to federal investigators, including the lie about how long he had known Zhukovskyy. Prosecutors asked for a year. On Nov. 21, 2024, U.S. District Judge Mark G. Mastroianni sentenced him to two months, 12 months of supervised release with no commercial driving, and a $300 special assessment.

Dartanyan tried to plead guilty in 2021, and the court didn’t accept the plea. He has pleaded not guilty since and is presumed innocent. His trial was set to start March 2, 2026, in Springfield before Mastroianni, and he reportedly turned down a plea offer with no prison time. Seven months after that date, I haven’t found a verdict, a plea, a dismissal, or a sentencing reported anywhere, and the U.S. Attorney’s Office in Massachusetts hasn’t announced one. If that case resolved quietly, nobody told the families.

The driver: acquitted in New Hampshire, a probation sentence in Connecticut six years late, a removal order on a shelf, and a suspension that ended in June. One owner: two months. The other: no public resolution. The carriers around them: some still running.

Why Dalilah’s Law, and why it’s not enough by itself

H.R. 5688 cleared the House Transportation and Infrastructure Committee 35-26 on March 18, 2026. As of today, it has gone 199 days without a floor vote. On July 15, the Owner-Operator Independent Drivers Association wrote Speaker Mike Johnson demanding one. Critics call the bill immigration policy dressed as road safety. Randolph is the case that answers them, because nothing about it turns on citizenship. It turns on paper.

Section 5 amends 49 U.S.C. 31311(a) to require every state to disqualify a driver from operating a commercial vehicle for the same reasons and periods another state disqualified him under 31310, and to act when DOT notifies it that a driver was convicted of an equivalent offense in a foreign country. It also amends 31310(g)(1) so the disqualification rules for serious offenses in a personal vehicle apply to drivers required to hold a CDL, not only drivers who happen to hold one.

Federal rules already told Massachusetts to post Connecticut’s report and act on it. The registry had the notice and didn’t open it. A state’s own audit after the crash found tens of thousands of out-of-state notices that were never entered into drivers’ records, and Registrar Erin Deveney resigned days after Randolph. Writing reciprocity into statute doesn’t make a clerk open a file. It gives DOT a clean statutory hook, and Section 4 attaches money to it by withholding federal highway funds from states that don’t comply. A backlog in a box becomes a line item a governor has to answer for. That’s the value.

Section 6 hits the same failure on the employer’s side. It orders the driver record notification system modernized within three years so carriers learn when a driver’s license status changes. A carrier that wanted to know would have known. A carrier that didn’t want to know would have had a harder time pretending.

What Dalilah’s Law doesn’t touch is the Gasanovs. It has no penalty for a carrier that knowingly puts a disqualified driver behind the wheel and nothing aimed at the affiliate web the NTSB mapped. On Sept. 28, Rep. Brandon Gill of Texas filed H.R. 10620, Barron’s Law, named for 8-year-old Barron Ritchey, killed on Interstate 35 near Hillsboro in April 2023. It would fine a carrier $25,000 for knowingly employing a driver who is ineligible under federal law, $100,000 if that leads to serious injury or death, deny registration for three years after a revocation, and fine any carrier $25,000 for using a successor or affiliated company to dodge a revocation or safety sanction. That last clause reads like it was written about East Transport and East2West.

Here’s the catch, and it’s the whole argument. On paper, Zhukovskyy wasn’t ineligible on June 18, 2019. His CDL was valid because Massachusetts never posted the Connecticut suspension. A carrier penalty keyed to ineligibility only bites if the state record is right, and the state record only matters if carriers have to check it before the first load, not 30 days after. Section 5 fixes the record. Section 6 pushes it to the employer. Barron’s Law, or something like it, makes ignoring it expensive. Pass the first one, and the next owner who hires a man he’s known for years, knowing his history, at least can’t hide behind a clean license.

The Jarheads were buried in 2019. The man who hit them has finished the longest suspension New Hampshire allows, the owner who lied about hiring him finished his two months, and the other owner’s case has gone quiet. The notice Connecticut sent is still the cheapest thing in this whole story to fix.

Congress has had it for 199 days.

Rogel Aguilera-Mederos becomes eligible for parole on Dec. 30, 2026, five years after Colorado's governor cut his 110-year sentence to 10. Castellano 03 Trucking dissolved months after the crash; a new company registered at the same Houston house the day after, and the four families split a $750,000 policy.

The lumber truck hauling 2x4s should never have been on Interstate 70 that April afternoon. Neither should its driver. Castellano 03 Trucking LLC had accumulated 30 safety violations in the two years before the crash, including violations for employing drivers who couldn’t read English highway signs. Interstate 70 in Colorado features numerous signs, all in English, between Genesee and Colorado Mills Parkway, warning truckers of steep grades, sharp curves, gear shifts, and the locations of runaway truck ramps.

At 4:30 p.m. on April 25, 2019, Rogel Lazaro Aguilera-Mederos lost control of his semi-trailer truck when his brakes failed while he was going down a mountainous stretch of Interstate 70. What followed was the destruction of four families, exposing a chameleon carrier operation and revealing how federal oversight systems fail when profits take precedence over people.

Aguilera-Mederos was first reported speeding as he passed Genesee (Exit 254). Video evidence would later show his truck smoking as he passed a runaway truck ramp without taking it, instead drifting into the left lane, nearly clipping a white Chevy Silverado. For the next several minutes, Aguilera-Mederos reached speeds upwards of 100 miles per hour and passed the next four exits.

The fatal trip was his first time driving a truck through the mountains, despite telling police he had mountain experience. On cross-examination, Deputy District Attorney Kayla Wildeman focused on inconsistencies between Aguilera-Mederos’ testimony and what he’d told police in an initial interview, including that he’d told investigators he’d previously driven in Colorado’s mountains. Families against mandatory minimums did call for an investigation into her office.

When pressed, Aguilera-Mederos said he’d misunderstood the police officers’ questions. “When I say mountain, I am referring to a small hill, and I am talking about dangerous hills going downwards,” he testified.

Police officers testified that Aguilera-Mederos hurtled down the interstate on the right shoulder during rush hour, chasing multiple cars off the side of the road to avoid being hit. As he gained speed, he started applying the trailer’s brakes. It didn’t work. Aguilera-Mederos then tried his truck’s emergency brake. That didn’t work either.

Aguilera-Mederos looked down at his speedometer and noticed he was going 85 mph. With a semitrailer blocking the right shoulder, Aguilera-Mederos swerved into stopped traffic. “He said he thought he was gonna die”.

The lumber from his trailer, combined with gasoline from smashed cars and mattresses from a Beautyrest truck, created instant fuel for explosions that would consume 28 vehicles and close I-70 for 24 hours.

The Victims

Four men died in the inferno: Miguel Angel Lamas Arellano, 24, William Bailey, 67, Doyle Harrison, 61, and Stanley Politano, 69. When his defense attorney asked about the four people who died, Aguilera-Mederos put his head in his arm and wept. “I feel very badly, I wish that it had been me”.

The systemic failures that enabled this tragedy continue today.

So Who Is Castellano 03 Trucking?

Castellano 03 Trucking LLC only had five trucks in its fleet, according to the Federal Motor Carrier Safety Administration. The Houston-based company operated under DOT number 3029296 and MC number 38540. Owner Yaimy Galan Segura gave a deposition after the accident and admitted she knew nothing about the trucking industry. She had a neighbor who owned a small company and was doing well. With advice from friends and research online, Yaimy started her own trucking company.

This is the classic profile of a chameleon carrier: an inexperienced operator running trucks with minimal insurance while accumulating violations. Castellano 03 Trucking carried only the minimum $750,000 in liability insurance, the federal minimum. Safety records show that Castellano 03 Trucking LLC has incurred multiple vehicle maintenance violations over the past 24 months, including 10 violations related to brakes or brake systems.

Usually, when I work with carriers or am an expert in highway accident litigation cases or insurance risk, violations like these that generally cannot be discovered by the driver in a pre-trip inspection, I refer to as systemic failures. That’s as opposed to driver-focused issues, where the driver could easily have found the defect and had it repaired. These systemic failures generally tell a story of management more than a bad driver, but they often go hand in hand.

The Shell Game

Castellano 03 Trucking, LLC dissolved a few months after the fatal crash. The day after the crash, on April 26, Volt Trucking LLC was registered as a business with the Texas Secretary of State’s Office. Both companies were registered at the same Houston home address, 12010 Fork Creek Dr.

The name of Yaimy Galan Segura, owner of Castellano 03 Trucking, appears on the signature line of a Texas Franchise Tax Public Information Report filed for Volt Trucking.

Same Players, Same Problems

According to inspection reports on the Federal Motor Carrier Safety Administration website, Volt Trucking LLC has been linked to at least 23 violations, including “inoperative/defective brakes” and “brake connections with leaks or constrictions”. Records show violations for “Brake connections with Constrictions Under Vehicle,” “Brake Connections with Leaks - Connection to Power Unit,” “Clamp or Roto type brake out-of-adjustment,” and “No or defective brake warning device or pressure gauge”.

So we dissolve the company with a bad safety record, register a new one the day after the crash, and keep operating with the same people and the same problems.

The NTSB didn’t get involved. That means no federal safety recommendations, no systematic analysis of contributing factors, and no pressure on FMCSA to address the regulatory failures that enabled this tragedy.

When asked why the NTSB didn’t investigate, Peter Knudson said the NTSB’s teams get involved when the agency sees an opportunity to issue new traffic safety recommendations. He said the agency opens investigations into between 15 and 20 of the estimated 8 million traffic accidents that occur in the US each year.

Four deaths, 28 vehicles destroyed, and systemic carrier safety failures don’t meet the threshold for federal investigation. The NTSB apparently saw no opportunity to issue safety recommendations in a case involving a chameleon carrier with 30 prior violations that employed a driver who couldn’t read English warning signs.

The Insurance

KKW Trucking won summary judgment on three of four claims in November 2020. The court awarded $97,723.81 in damages for the replacement cost of its tractor-trailer, the value of its lost cargo, and the workers’ compensation benefits paid to the driver. The problem is that KKW's attorney reported that Castellano had leased trucks and no assets to collect the award.

This is the deliberate business model. Run trucks on minimum insurance, lease equipment to avoid assets, accumulate violations until a major crash occurs, then dissolve and restart under a new name. The victims and their families fight over whatever scraps remain from a $750,000 policy split among multiple claimants unless they find other parties to sue.

The Legal Circus

Aguilera-Mederos was initially sentenced to 110 years in prison, but Governor Jared Polis commuted his sentence to 10 years with parole eligibility on December 30, 2026. Nearly 5 million people signed a petition calling for clemency, including celebrities like Kim Kardashian.

People rallied around Aguilera-Mederos with the hashtag #NoTrucksToColorado, arguing the sentence was excessive for what they called an accident. Kyle Bachus, representing survivor Leslie Ross, said: “It is also extremely difficult for victims to understand how the State of Texas ever allowed these same people to reopen and operate under another trucking company under a different name after they destroyed so many families.”

So…Where They Are Now

Aguilera-Mederos is serving his 10-year sentence and will be eligible for parole on December 30, 2026. Next year! Meanwhile, the company structure continues. Yaimy Galan Segura received a $2,347 PPP loan in April 2021 for “General Freight Trucking, Local”, indicating continued trucking operations.

The Texas Franchise Tax Public Information Report filed by Volt Trucking LLC for the 2021 reporting year lists Rafael Perez Rodriguez as the sole owner and officer, with Yaimy G. G. Segura signing the document and declaring the information accurate and correct.

The same address. The same players. The same pattern of brake violations. Different company name.

The System Working as Designed

This wasn’t an accident. This was the predictable result of a system designed to protect carriers at the expense of public safety. Castellano 03 employed drivers who couldn’t understand English warning signs on a mountain pass loaded with hazards. They accumulated 30 violations in two years without losing their authority. They carried minimum insurance while operating equipment with documented brake problems. When the inevitable happened, they dissolved and restarted operations the next day.

FMCSA knew about the violations. Texas regulators knew about the company’s issues. The Colorado DOT knew about the brake-check areas where trucks were overheating. The NTSB chose not to investigate despite apparent systemic failures. Everyone knew. Nobody acted. Four people died.

Media outlets have reported on these cases for years, but now seem outraged. They report; attention disappears because we have short memories, and that’s it. It’s over. Now there’s interest. There’s an agenda, so we revert back to day 2 of the series.

The most telling detail isn’t Aguilera-Mederos’s 10-year sentence or the company’s chameleon tactics. It’s what didn’t happen. No NTSB investigation means no safety recommendations. No federal pressure on FMCSA to tighten oversight of small carriers. No requirement for enhanced insurance minimums. No changes to the carrier registration system that allows dissolved companies to restart operations immediately. In yet another case, the driver goes to prison, and ownership and management move on. The same applies to Danny Tiner in AZ’s TikTok crash and Richard Hutchinson Wright in the VA Ashley Chapman crash. The driver faces the consequences; the owner starts a new business, maybe pays some money as the cost of doing business, and life goes on. The driver’s life and career are over.

Segura disputed over $10,000 in fines through arbitration, fighting violations including 49 CFR 382.301(a) for allowing drivers to perform safety-sensitive functions without proper controlled substance testing. She spent more energy fighting regulatory fines than preventing the crash that killed four people.

Where Dalilah’s Law fits

Section 6 of Dalilah’s Law lets FMCSA withhold, suspend, or revoke a carrier’s registration when it knowingly uses a driver who doesn’t hold a CDL issued to federal standards or can’t meet the English requirement. Castellano’s inspection record carried English violations, and under the bill those would be grounds for registration action on their own, not just roadside citations. Section 2 would make a first English out-of-service order a disqualifying offense for the driver.

The bill wouldn’t have fixed the brakes, the runaway ramp decision, a new carrier registered at the same house the next day, or a $750,000 minimum that hasn’t moved since 1985. Nothing in Dalilah’s Law addresses insurance minimums, and FMCSA’s chameleon screening is the only federal tool aimed at Volt Trucking. The BUILD America 250 Act, H.R. 8870, doesn’t raise the minimum either. My view hasn’t changed: coverage should scale with fleet size, so a 5,000-truck carrier and a five-truck carrier don’t carry the same floor.

The driver who lost his brakes served five years and will go before a parole board. The owner who ran a five-truck company with 10 brake violations in two years went on to sign paperwork for the next one. The four families got a share of $750,000.

The Real Questions

Why did FMCSA allow Castellano 03 to continue operating with 30 violations? Why haven’t we required meaningful minimums for insurance? OOIDA opposes raising coverage minimums, but I believe coverage should be on a sliding scale. A trucking company with 5000 trucks should not have the same minimum as a company with two trucks, another argument for another day. Why can carriers dissolve and restart operations the day after a fatal crash? Why did the NTSB decline to investigate systemic failures that enabled this tragedy?

The answers suggest a regulatory system designed to protect industry profits, rather than public safety. Carriers operate with minimum insurance, knowing they can dissolve after major crashes. Regulators issue violations they rarely enforce meaningfully. Federal agencies avoid investigations that might require uncomfortable recommendations about systemic change.

Volt Trucking went on to operate from the same address, with the same ownership structure, and faces the same brake violations that defined its predecessor. The newer business has been linked to at least 23 violations, including “inoperative/defective brakes” and “brake connections with leaks or constrictions.” Per Texas Corp records, Volt is closed.

The families of Miguel Angel Lamas Arellano, William Bailey, Doyle Harrison, and Stanley Politano received their final settlement checks from a $750,000 policy divided among multiple claimants. Meanwhile, the same people who employed their killer continued hauling freight with defective brakes under a different company name.

This is American transportation safety in action. Four families destroyed, one driver serving reduced time, and a regulatory system that enables it all while protecting the very people who profit from carnage.

As a driver, I often wanted to know where I'd stop, where enforcement was heavy, where crash risk was high, etc., so I could better plan my trip.

As a carrier, I wanted to work with the best shippers and brokers to make sure I’d be paid and the load made money.

As a broker, I wanted the best carriers to not only get my freight to its destination but also keep my shipper happy.

As a risk guy, I wanted to make sure our clients understood what risk meant beyond compliance.

I realized all of this required a tremendous amount of networking power. I also realized that identity, disclosure, and accountability are key. So we built what amounts to a planning networking load board that is free to access, but the minute you want to interact, you've got to validate with facial recognition. From there, you can post loads, post a truck, post a job, apply for a job, plan your route, and post a service as a vendor, but we don't do anonymous. We even dropped the flock sensors into the map because this app is about identity and transparency as much as it is about networking and industry connection.

Let’s run through a load. Yorktown, Virginia, to Elk Grove Village, Illinois. 882 loaded miles, 146 deadhead, a dry van getting 7.1 miles per gallon. Somebody offers $2,500. It sounds like real money until you do the math. Fuel across six states comes to $928. Fixed costs, wear, and driver pay bring the total to $2,833, or $3.21 a mile. The $2,500 offer pays $2.83 a mile. You’d be paying to haul it.

Araynge did that math in about a second, state by state, using this week’s diesel price for each region and each state’s fuel tax. The verdict at the top says below cost. A 15% margin on that lane needs $3,333. That’s the number to counter with, and now you know it before you pick up the phone.

Cost to run prices the lane state by state against this week’s diesel and fuel taxes, then tells you whether the offered rate covers it.

Every industry seat has the same problem. The information exists, but it's scattered. The route lived on a phone, the clearance on a sign, the scale report on the CB, the state’s rules on a website, the carrier’s record in a federal database, and the load in a text message. Araynge is the map I wanted in every one of those seats. Building it was the most fun I’ve had this year.

A route built for your truck

Routing starts with the truck, not the destination. Put your truck on file: height, width, length, gross weight, and axles. Decode the VIN, and Araynge fills in the engine and typical fuel economy. Hazmat is built in by class, with bulk, highway-route-controlled quantity, inhalation-hazard flags, and the UN number. Araynge builds a large-vehicle route across the lower 48. Then it runs a second check along the line for everything a router misses: low clearances against your height, posted and closed bridges, hazmat restrictions and tunnels, railroad crossings with hump warnings for low trailers, and mountain grades with their length, percent, and truck speed limit.

Routing that knows your truck: dimensions, weight, axles, and hazmat on file, checked against route restrictions.

Here’s what that looks like on an oversize demo load from Chicago to Columbus, Ohio, at 16 feet tall. Araynge flags five low clearances on the route, from 12 feet up to 13 feet 11 inches, each one a problem for a 16-foot load. It lists the permit each state requires for a load over the legal 13 feet 6 inches, with the permit office phone number for Indiana, Ohio, and Illinois. It counts three weigh stations on the way, flags a planned overnight ramp closure, and checks the trip against a driver’s fresh hours-of-service clock. That’s a sample load in demo mode, labeled as one. The checks are the same on a real one.

A sample oversize load shows five low clearances, the required state permits and permit office numbers, three weigh stations, and an overnight closure. Demo data.

Hours of service are built into the route. Range shows how far you can get from where you are in 2, 4, 8, and 11 hours of driving, 11 being the federal driving limit under 49 CFR 395.3, and filters the truck stops and parking on the map to what’s actually inside each band. The panel tells you plainly that those bands use car drive times, not truck routing, so they’re for seeing what’s roughly in reach. The Route tab does the real truck planning.

Range shows how far you can drive in 2, 4, 8, and 11 hours and counts the truck stops and parking inside each band. The position is blurred. Best part: you can also ask the system what the optimal stops are within 2, 4, 8, and 11 hours.

What’s down the road

Parking is where a driver’s day goes wrong. In the Federal Highway Administration’s Jason’s Law truck parking survey, more than 75% of truck drivers said they regularly have trouble finding safe parking when they need rest, and 90% said it’s worst at night. Araynge shows Truck Parking Club listings and more than 5,600 public rest areas and lots, plus weather and live 511 incidents along the route, so you can see the storm and closures before you get there.

Weather over the route, plus a Truck Parking Club listing of open spaces, lighting, and cameras.

Every weigh station on the map is colored by what drivers reported in the last two hours. Roll toward one, and an alert fires within 15 miles; one tap reports it open or closed for the next driver. Tap a state, and Araynge shows whether it adopted the federal regulations, its weight threshold, whether it issues citations, and its diesel tax, each dated and linked to the official source.

Scales are colored by recent driver reports, traffic cameras, live 511 incidents, and each state's rules.

State-by-state trucking and Firearm carry rules: FMCSR adoption, the 26,000-pound weight threshold and its citation, and the state diesel tax, with the date and source.

Broken down at 2 a.m., a general search engine fails a truck driver worst. Araynge’s service layers show who can come to you: 2,070 truck repair and tire shops, 1,262 towing listings and 56 mobile roadside services, each with a phone number. The site also lists 2,157 CAT scales, 1,509 weigh stations, truck and trailer dealers, CDL schools, DOT physical providers, 24-hour pharmacies, hospitals, and police. Vendors who claim their listing and switch it to open show up first.

Every layer runs on one toggle: route hazards, mountain grades, enforcement, freight nodes, services, and live data.

Know the lane before you take the load

Type an origin and a destination, and Lane frequency shows what happened along that road in the last two years. On the Yorktown to Elk Grove Village run, within 25 miles of the line, that’s 57 inspection sites, 89 counties with 113,741 inspections and 176,365 violations, 21,186 of them out-of-service, and 23,261 crashes, 425 of them fatal. Tap a county for its details. Frederick County, Maryland, alone logged 11,774 violations on 6,694 inspections, with 2,072 inspections ending in an out-of-service order. The panel also lists the carriers inspected most often in those states. Every number is a count from FMCSA records, not a score, and the page says so.

Lane frequency counts the inspections, violations, and crashes within 25 miles of the route over 24 months. Origin and carrier names are blurred.

Review a lane alongside its operating cost, including USDA produce rates from shipping points like Salinas and Nogales.

Hauling produce? The USDA shipping points are on the map with this week’s truck rate to each city, the change from last week, and whether trucks are short. The freight market sits across the top of the map: the producer price index for long-distance truckload was 207.6 in August, up 13.9% from a year earlier, according to the Federal Reserve’s FRED data.

The load board, with people you can check

A carrier posts a truck as empty and available, or as a backhaul showing where it’s trying to get to. A broker or shipper posts a load with origin, destination, equipment, weight, oversize, hazmat by UN number, and a minimum vetting score for who can respond. Verified carriers answer, and the parties contract directly. Araynge never touches the freight money.

Post a truck or a backhaul, or post a load with a minimum vetting score for responders.

Every load card does the cost math too. On a sample Chicago to Columbus dry van load posted at $980, Araynge works out 431 total miles with deadhead and an all-in cost of $1,114. That means the driver loses $134 at the posted rate, and $1,300 is the counter that lands a 15% margin. One tap sends the quote.

A sample load shows it loses money at the posted rate and suggests a counter. Demo data.

Fake loads and double brokering start with people pretending to be somebody else, so trust is built into the map. Everyone who acts on it verifies their identity once with a government ID and a selfie. Then they attach a credential: a CDL, DOT authority plus insurance, or broker authority plus a bond. You choose what others see, and a coarse location stays coarse until you match. Verify once, and Araynge, LoadVerifi, CarrierVerifi, and DriverVerifi all recognize it.

Verify once with an ID and a selfie, attach a working credential, and choose what others see.

Behind every Pin is the public record. Tap a carrier or broker to see the legal name, DOT and MC, authority and insurance on file, the process agent, officers, power units, drivers, safety rating, and the MCS-150 dates. You also get a Street View frame of the listed address, labeled yard, storefront, residence, or mail drop, with a count of how many other carriers share it. You can see before you book whether a broker's office is an apartment.

Carrier and broker cards show the FMCSA record and a labeled Street View of the listed address. Names and details are blurred.

Jobs, data, and who it’s for

CDL jobs and the office, shop, and yard jobs behind them show on the map as one pin per city. Each employer is matched to its FMCSA record, so a driver sees who they’d be working for before they apply. Carriers post jobs with their badges, and drivers can flag themselves open to work.

CDL jobs on the map, each employer matched to its FMCSA record. Employer details are blurred.

The Data tab turns the same public records into 14 pages: inspections, crashes, insurers, shippers, hazmat incidents, broker bonds, ELDT schools, plus market data from FRED, Cass, the EIA and USDA. Every chart names its source and as-of date and downloads as a CSV. They’re counts, not grades.

The Data tab’s market page charts FRED freight series with year-over-year change, the truckload index against truck tonnage, and Cass expenditures per shipment.

Araynge is built for drivers, carriers, shippers, brokers, vendors, and the industry’s safety, compliance, and research staff.

What it costs

An account is free and stays free. That covers the whole map and every layer, the Data pages, the safety benchmark, the job boards and the logbook for drivers exempt from the ELD rule, with loads and truck posts shown without names. Verification is $5 once, ID plus selfie. Truck routing with restriction checks, clock stops, fuel, and profit is the Driver seat at $9.99 a month. Carriers, brokers, and shippers who post, quote, and see who’s behind a listing buy a seat, and every seat includes verification.

Araynge runs today in any browser, on the desktop at a broker’s desk or on the phone in the cab. On Android, you can install it to your home screen straight from the website. The App Store and Google Play versions are in review now.

Everything on this map was already public: the clearance in the bridge inventory, the crossing in the federal file, the crash in FMCSA’s records, the diesel price at the EIA. What drivers and brokers never had was all of it on one screen when they had to decide.

That $2,500 load is still out there. Now you know what it costs before you take it, who posted it, who’s bidding to run it, and where their truck is in respect to the load.

Rob Carpenter is the founder of Tea Technologies, Inc., which owns Araynge, LoadVerifi, CarrierVerifi, and THE TEA Highway Intelligence Platform. He is vice president of compliance at TruckSafe Consulting and an expert witness in commercial motor vehicle litigation.

For years, over a decade, I’ve been paid by folks from the tech community to advise on their builds to ensure the fleet tech we all rely on today is operationally efficient and useful, but also compliant and risk-focused. I always said that, as much as you Y-Combinator, VC, PE, programmers, developers, and product managers pay me to advise on building systems that meet operational and regulatory requirements, if I ever learn to build these things, you’re in trouble. We learned and are still learning to build, but since February we’ve pushed out some stuff. Not everyone’s in love with it, and that’s fine. Unfortunately, competition has a way of showing whether we’re in this for the betterment of the industry or to make dollars, and the dollar chasers have surprised me. Over our 15 years in app and fleet tech consulting, we’ve focused on building real tools that solve real problems.

Hazmat and dangerous goods is probably the most sensitive freight on our highways, and even drivers like me with Hazmat endorsements don’t always understand which placards to use. When to use which placards. When commodities require segregation. When more than one placard is needed. When no placard is needed but training is still required. What’s ERG? What’s routing? What and how do I segregate? If I have a crash and/or spill, who do I call?

Hazmatverifi is a browser-based tool, but we’re working on the Android and iOS rollout and approval. It’s mostly free. There is a fee if you use the shipping paper and load build functions, but all the knowledge-based portions are free. You can add it to LoadVerify and build the load and shipping papers with QR code, telematics tracking, and driver/vehicle verification.

Let’s build a hazmat load. Instead of two thousand pounds of 1,3-dimethylbutylamine, a Class 3 flammable liquid, and 2,500 pounds of a Division 4.1 flammable solid. Same trailer, same trip. The first question is easy: at 4,500 pounds aggregate, both materials need placards. The second question is where people get it wrong. Can you hang one DANGEROUS placard instead of FLAMMABLE and FLAMMABLE SOLID?

The rule says you can, sometimes. Under 49 CFR 172.504(b), a vehicle carrying two or more categories of Table 2 materials in non-bulk packages may use the DANGEROUS placard instead of separate placards. Then comes the exception. When 2,205 pounds or more of one category is loaded at one facility, use that category’s placard. The flammable solid on this load is 2,500 pounds. FLAMMABLE SOLID goes on the truck, DANGEROUS or not.

The same result flags the DANGEROUS placard option under 49 CFR 172.504(b) and tells the user to check the single-category exception before substituting.

After a release, the questions are nearly always the same. What was on the truck? Was it marked the way the rules say? Was it loaded next to something it shouldn’t have been? None of those answers are secret. They sit in federal tables anyone can read, if you know which table and you have time to read it at a shipping dock at 2 a.m.

That’s the reason for HazmatVerifi. The Hazardous Materials Table lives in 49 CFR 172.101. The placarding rules live in 172.504. The highway segregation table lives in 177.848. First-response guidance lives in PHMSA’s Emergency Response Guidebook, the paperback in the door pocket. State route restrictions live on an FMCSA registry. HazmatVerifi puts all of it in one place, and every reference tool on it is free, no account required.

HazmatVerifi searches by UN number or shipping name, with Load Check, the segregation matrix, and the Class 1 compatibility table one tap away.

The stakes aren’t abstract. In 2025, the PHMSA incident data recorded 25,447 hazardous materials incident reports from highway transportation, 93% of every hazmat incident report filed across highway, air, rail, and water that year. Most of those are small releases that never make the news. All of them start with somebody on a dock or in a cab making a call about what’s in the trailer.

Load Check is where most people start. You add every hazmat on the load by UN number or shipping name, or by hazard class when you don’t have the number handy. Each result shows its hazard class, packing group, and ERG guide number as you type. Enter quantities in pounds, kilograms, gallons, or liters, and Load Check returns the required placards, segregation conflicts, and any Class 1 explosives compatibility problems. The placard math follows 172.504. Table 1 materials, such as Poison Gas and Dangerous When Wet, get placarded at any quantity. Table 2 materials don’t need placards until the vehicle carries 1,001 pounds or more of them in aggregate. The bar across the result shows exactly where your load sits against that line.

Load Check searches the Hazardous Materials Table as you type, showing each entry’s hazard class, packing group, and ERG guide.

That 1,001-pound line has a limit you need to know. It doesn’t apply to bulk packagings. A cargo tank of gasoline gets placarded at any quantity, and Load Check doesn’t ask whether your packaging is bulk. Every result ends with the same line: guidance only; the shipper is responsible under 49 CFR Parts 100 through 185; verify against the shipping papers. The tool does the arithmetic. The shipper still signs the paper.

Segregation comes back on the same screen, and the full table has its own page. In the 177.848 highway segregation table, an X means two classes may not be loaded, transported, or stored together in the same vehicle. An O means they can share the vehicle only if they’re separated so the materials couldn’t mix if a package leaked. An asterisk sends you to the Class 1 explosives compatibility table. Tap any cell for the details, or open the regulation text right there.

The 49 CFR 177.848 highway segregation matrix: X means prohibited together, O means must be separated, and an asterisk points to the Class 1 table.

When something goes wrong, the order matters, and the emergency page is built for a phone in a shaking hand. Call 911 first. Then call the emergency response number on the shipping paper, which the rules require to be monitored the entire time the material is in transportation. Then report the release to the National Response Center at 800-424-8802. Under 49 CFR 171.15, the person in physical possession of the material must call the NRC to report a reportable incident as soon as practical, and no later than 12 hours after it happens. The page also says what people often miss: calling a private emergency response service doesn’t satisfy the NRC requirement.

The emergency page puts 911, the shipping paper’s emergency number, and the National Response Center in the order to call them.

The site carries the full 2024 Emergency Response Guidebook from PHMSA, Transport Canada, and Mexico’s transportation ministry. That’s all 64 guides, from Guide 111 for mixed loads and unidentified cargo through the gases, flammables, toxics and corrosives, searchable by UN number or shipping name. Every material page links to its guide, so a first responder or driver can go from four digits on a placard to the right guide in one tap.

The 2024 Emergency Response Guidebook on HazmatVerifi, searchable by UN number or name, with every guide listed.

Routing is part of the job too. The routes page pulls designated and restricted hazmat routes state by state from FMCSA’s National Hazardous Materials Route Registry, with a reminder to confirm current restrictions with the state before dispatch, because designations change. The guidance library collects official federal, state, and industry publications by commodity, from ammonium nitrate and anhydrous ammonia to cargo tank rollover prevention and chlorine.

Designated hazmat routes by state from the FMCSA National Hazardous Materials Route Registry.

The guidance library organizes official hazmat publications by commodity and topic.

Knowing the rule isn’t the same as being trained on it, and the regulation says so. Under 49 CFR 172.704, every hazmat employee needs training in four areas: general awareness and familiarization, function-specific duties, safety, and security awareness. That training has to be repeated at least once every three years. HazmatVerifi’s training page explains the requirement and links to function-specific hazmat training from TruckSafe Consulting. Full disclosure: I’m vice president of compliance at TruckSafe.

The training page explains the 49 CFR 172 Subpart H requirement and links to TruckSafe Consulting’s hazmat training.

Everything above is free: the lookup, every ERG guide, the segregation checker, Class 1 compatibility, routes, the guidance library, and Load Check for up to three materials per load, with no account. Pro is $9 a month or $90 a year. It removes the three-material limit, saves loads so a dispatcher can rerun a regular mix without rebuilding it, and prints a one-page load summary. That summary is a planning worksheet, not a shipping paper. The person offering the material still certifies the shipping paper.

Every reference tool stays free. Pro adds unlimited materials, saved loads, and printable summaries for $ 9/month or $90/year.

The hazmat rules were always public. What a driver or a dispatcher never had was all of it on one phone screen, in the order the job asks for it: what it is, what goes on the truck, what can’t ride together, and who to call when it goes wrong.

The 2,500 pounds of flammable solid on that load was never a trick question. It was a table lookup and some arithmetic. The trouble was always finding the table.

Rob Carpenter founded Tea Technologies, Inc., which owns HazmatVerifi and THE TEA Highway Intelligence Platform. He is vice president of compliance at TruckSafe Consulting and serves as an expert witness in commercial motor vehicle litigation